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Date: 28 Nov 2007 01:57:05
From: Sam Sloan
Subject: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
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Sam Sloan
1664 Davidson Ave., Apt. 1B
Bronx NY 10453-7877
Tel. 917-507-7226
[email protected]
November 27, 2007
Referee Mildred Negron
Queens County Family Court
151-20 Jamaica Avenue
Jamaica NY 11432
Re: Sloan vs. Rankoth, V-11657-05
Rankoth vs. Sloan, O-18182-05
Dear Referee Negron,
You may recall that the court ordered that I would have one visitation
with my daughter Anusha, now aged 15, but then it was reported that
although Anusha came to the scheduled visitation she refused to see
me.
However, I have since learned from other sources that Anusha did not
come alone. She was accompanied by a representative of Dorschen
Leidholdt�s office, although not by Dorschen Leidholdt herself.
My appellate counsel, Pauline Braun, informs me that this was entirely
improper. It was OK for Anusha to be accompanied by her mother,
another close relative or even by the Guardian Ad Litem. However,
Dorschen Leidholdt has been in an adversary relationship with me for
16 years since June 1991 and she had been manipulating and controlling
my children and their mother for that entire time. Indeed, Dorschen
Leidholdt tried to abortion my daughter Anusha, since Dayawathie was
pregnant with Anusha when Dorchen first got involved with her in 1991.
Dayawathie has often told me that the only thing that saved Anusha�s
life was that Dorschen could not arrange the Medicaid in time to pay
for the abortion and by the time the Medicaid was available the
pregnancy was too far advanced for the abortion.
However, Dorschen Liedholdt did abortion our next baby. Dayawathie
became pregnant with our next baby in 1995 and Dorshen had that baby
abortioned on July 7, 1995. The abortion of Sam Sloan's child took
place on July 7, 1995. Almost immediately thereafter, Dayawathie
became pregnant from a passing stranger whose name and identity is
still unknown. That child, Geeta Kamal Rankoth, was born on June 9,
1996, just 11 months after Dayawathie's child by Sam Sloan had been
aborted. By that time, the father of Geeta had long since disappeared.
Geeta, incidentally, is a bright and delightful child.
As to how Dorschen Leidholdt is able to control Dayawathie to the
extent of moving her about, directing where she should live and even
deciding whether she should have an abortion or not, it is a carrot
and stick operation. Dayawathie has been under constant investigation
by ACS since she first arrived in New York in June 1991. She was also
being investigated by Childrens Services in Lynchburg Virginia before
she got here. She has also been threatened with eviction proceedings.
Dorschen Leidholdt appears and defends her in all these cases. I have
some evidence that she actually helps brings these cases that she then
defends her in.
Dorschen Leidholdt had my two sons, Michael and George, kidnapped away
from me in May 1995. We were living in San Francisco with the
knowledge and consent of Dayawathie who was trying to keep this fact a
secret from Dorschen Leidholdt.
This story goes on and on. I could write a book about it and perhaps I
will some day.
What is especially disturbing about Dorschen Leidholdt is that she is
an outspoken advocate of lesbianism. I am a strong believer that
people have a right to adopt their own lifestyles and to fulfill their
own dreams, whatever they may be. I have no objection, none what ever,
to Dorschen Leidholdt being a lesbian. I do object, however, to her
having any involvement in raising my daughter. If you will read her
book, "The Sexual Liberals and the Attack on Feminism", by Dorschen
Leidholdt, you will see her advocating lesbianism and claiming for
example that one-quarter of all girls under age ten have been sexually
molested usually by their own fathers. This is a sick statement for
which she offers no proof. Dorschen Leidholdt has also been personally
involved with infamous pornographers including Linda Lovelace and
Larry Flynt. I want this woman kept away from my children and I have
every right to insist on that.
While this case was pending before Judge Modica, I made several
motions to disqualify Dorschen Leidholdt and her representatives,
including Jill Zuccardy and Alexander Karam, from appearing in this
case. These motions were properly served and submitted in open court
by handing them up to the judge. I went to the court last week to look
at the file and found that there was no record of these motions. They
were not in the file or on the docket. Apparently, Judge Modica must
have trashed them.
Apparently, needed to file them with Mr. Sternberg on the first
floor. I did not know about that. I naturally assumed that handing
them up to the judge in open court was an effective way to file these
motions. I ask that you consider these motions now.
Also, I ask that you reschedule my visitation with Anusha and direct
Dorschen Leidholdt and her representative to stop interference with
this case.
Every time I bring up Dorschen Leidholdt I am told that she is not in
this case. But, she is in this case. Dorschen Leidholdt is the 800
pound gorilla in the room. She controls Dayawathie Rankoth. She hires
and fires Jill Zuccardy, Paul Weiss and the other attorneys who appear
in this case, and every time I try to ask Dayawathie a question about
Dorschen Leidholdt the attorneys object on the grounds of
attorney-client privilege, yet the name of Dorschen Leidholdt has
never appeared on any of these cases.
I have never met or seen Dorschen Leidholdt. I have no idea what she
looks like. I know her role in this case because Dayawathie talks
about her and often complains about her all the time. This case will
never be resolved and will go on forever as long as Dorschgen
Leidholdt is allowed to hide behind a screen while controlling and
manipulating everything.
Accordingly, I am renewing my motions previously filed with Judge
Modica to remove Dorschen Leidholdt from this case.
I also object that every time that Jill Zuccardy announces her
appearance in this case she states that she is representing Sanctuary
for Families. Center for Battered Women�s Legal Services. This creates
the misleading impression that Dayawathie Rankoth is a battered woman.
However, there is no allegation, much less evidence that she has ever
been battered by me. Also, the 990 Form for Sanctuary for Families
shows that Dorschen Leidholdt pays herself a salary of $111,067 per
year. She is just using my family as poster children so that she can
obtain charitable contributions and this is highly objectionable.
Then, she uses this as a pretext to get Paul, Weiss, Rifkind, Wharton
& Garrison to represent Dayawathie Rankoth on the appellate level.
On May 2, 2006 in an article in the New York Law Journal in response
to criticism of the judges in the Queens Family Court, Dorschen
Leidholdt was quoted as saying that most of the judges are bad, but
there is one good judge and that is Judge Modica. I would like to draw
your attention to that quote.
Very Truly Yours,
Samuel H. Sloan
Copy to:
Jill Zuccardy
Vladimir Cadet
Janet L. Brown
Pauline Braun
Paul, Weiss, Rifkind, Wharton & Garrison LLP
P.S. While not relevant to this case, I think I should inform you that
there has been a lot of media publicity recently about the fact that a
person has been positively identified as having impersonated me in
2464 postings on the Internet.
The lead article on this subject appeared in the New York Times on
October 8, 2007 entitled: NY Times: "Chess Group Officials Accused of
Using Internet to Hurt Rivals"
AFFIDAVIT OF SERVICE
Docket No. V-11567-05
STATE OF NEW YORK
COUNTY OF QUEENS
Kayo Kimura, being duly sworn says: I am not a party to this action, I
am over 18 years of age and on November 27, 2007 at 8:00 AM I served a
true copy of the within motion by mailing a true copy of the same to:
Jill Zuccardy
Sanctuary for Families
67 Wall Street, Room 2211
New York NY 2006
Vladimir Cadet
89-31 161st Street, Suite 505
Jamaica NY 11432
Janet Lisa Brown
89-31 161st Street, Suite 301
Jamaica, NY 11432-6150
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas
New York, NY 10019-6064
__________________________
Sworn to Before me this 27th
Day of November, 2007
______________________________
NOTARY PUBLIC
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Date: 03 Jul 2008 17:54:18
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
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Sam Sloan
1664 Davidson
Ave., Apt. 1B
Bronx NY
10453-7877
Tel.
917-507-7226
[email protected]
June 30, 2008
Jackie Vasquez
Appellate Division, Second Department
Supreme Court of New York
45 Monroe Place
Brooklyn, NY 11201
2008-02071
In the Matter
of Dayawathie Rankoth,
respondent, v
Samuel Sloan, appellant.
Dear Ms. Vasquez,
With regard to our conversation earlier today, the scheduling order
gives me until today, June 30, 2008 to file my brief. However, in this
case, the transcripts are, according to my count, 516 pages long.
There are hundreds of pages of exhibits and related documents. This
case was filed on July 30, 2005 and litigated for more than two years
over eight hearing dates involving live testimony of witnesses.
Accordingly, it will not be possible for me to file my brief today. I
am working very hard on it and I expect to be able to file my brief in
two weeks.
I hereby request an extension of time of 30 days to file my brief.
Very Truly
Yours,
Sam Sloan
Copy to:
Jill Zuccardy
Attorney for Sanctuary for Families
67 Wall Street, Suite 2211
New York NY 10006
Vladimir Cadet
89-31 161st Street, Suite 505
Jamaica NY 11432
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Date: 19 May 2008 23:30:29
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
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SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: SECOND DEPARTMENT
------------------------------------------X
No. 2008-02071
DAYAWATHIE RANKOTH,
Docket No. O-18182-05
Petitioner - Respondent
Queens County Family Court
- against -
MOTION TO DISQUALIFY
SAMUEL SLOAN, Jill
M. Zuccardy and
Sanctuary for Families, Inc.
, Respondent-Appellant. from
appearing as counsel
------------------------------------------X
in this case
AFFIDAVIT IN SUPPORT OF MOTION TO DISQUALIFY Jill M. Zuccardy and
Sanctuary for Families, Inc. from appearing as counsel in this case:
Samuel H. Sloan, being duly sworn, deposes and says:
1. I am the Respondent-Appellant in the above entitled case. I make
this motion to disqualify Jill M. Zuccardy and Sanctuary for Families,
Inc. from appearing as counsel in this case.
2. JILL M. ZUCCARDY begins her affirmation to dismiss my appeal with
the following paragraph:
�1. I am a pro bono attorney associated with Sanctuary for Families'
Center for Battered Women's Legal Services.�
3. This statement alone is unfair and prejudicial. It implies that
Dayawathie Rankoth, the Petitioner - Respondent herein, is a �battered
woman�. In reality this is not the case. There is no allegation, much
less evidence or proof, that Dayawathie Rankoth has ever been
battered, abused or mistreated in any way.
4. In addition, these statements have the effect of threatening and
intimidating the judges of this and other courts. If the judges decide
a case contrary to the wishes of Dorchen Leidholdt, she will go to the
newspapers and complain that the courts are failing to protect
battered women and that the courts themselves are abusers of women.
Dorchen Leidholdt often does exactly this. Search the newspapers and
you will see Dorchen Leidholdt often complaining about judges and the
courts. Dorchen Leidholdt is managing director, founder and CEO of
Sanctuary for Families. She had to make a great personal sacrifice to
do this, by giving up her career as a child pornography gadfly.
5. You heard that exactly right. Attached hereto is a feature article
about Dorchen Leiodholdt as published in Hustler Magazine. Dorchen
Leidholdt first became famous as a target of the Meese Commission on
Child Pornography.
6. In an article published in May 2006 in the New York Law Journal,
Dorschen Leidholdt was quoted as saying that all of the judges of the
Queens Family Court are bad except that there is one good judge. His
name was Judge Modica. Judge Modica happens to be the judge on this
case.
7. Jill M. Zuccardy works for Dorchen Leidholdt. She should not be
allowed to appear in this case.
.
.8. Sanctuary for Families is not a registered and licensed law firm.
The last time this case was before this court, Dorchen Leidholdt had
hired Paul, Weiss, Rifkind, Wharton & Garrisonto appear in this case.
It is apparent that Paul Weiss has seen the light and does not want to
appear any more. Probably this was pro bono work because they thought
they were representing a �battered woman�. Having found out that there
is no battered woman involved in this case, they have discharged their
duties and no longer want to be involved.
.
9. Attached hereto as an exhibit is the Form 990 for Sanctuary for
Families proving that Dorchen Leidholdt is the managing director of
Sanctuary for Families, Inc. Attached hereto as another exhibit is a
non-pornographic feature article about Dorchen Leidholdt from Hustler
Magazine. Attached hereto as a third exhibit is the cover of a book by
Dorechen Leidholdt entitled �The Sexual Liberals and the Attack on
Feminism�.
.
.10. Dorchen is a notorious lesbian activist. She should not be
allowed to have contact with anybodies children, and especially not
with my children. I can only wonder what the orientation of Jill
Zuccardy is, since she works for Dorchen Leidholdt. My assigned
counsel in the prior appeal to this court, Pauline Brandt, told me
that she is quite familiar with Dorchen Leidholdt and Sanctuary for
Families, having opposed them in many cases in the Family Court. She
said that they are �crusaders�, in the words of Pauline Brandt. They
are not concerned with the mother and her children in the case before
the courts. They want to make a political or social point. For
example, Dorschen Leidholdt campaigns against the �Mail Order Bride
Industry�. That may explain her interest in this case as she is
regarding Dayawathie Rankoth, who is from Sri Lanka, as some sort of
mail order bride.
11. The duty of any attorney is to her client. However, the priy
duty of Jill Zuccardy is to her boss, Dorchen Leidholdt. Therefore
Jill Zuccardy should be disqualified from appearing in this case.
.
.12. This is not just a minor point. This is the whole case. Dorchen
Leidholdt has been attacking me and my family for 17 years since June
1991. If Dorchen Leidholdt and her organization Sanctuary for Families
Inc. and their employee Jill Zuccardy is disqualified from this case,
this case will be over and I can get my children and their mother
back. The mother, Dayawathie Rankoth, is mortally afraid of Dorchen
Leidholdt and has told me all about this, which is the reason why I
know so much about her.
.
.13, I make this affidavit in support of a motion to disqualify Jill
Zuccardy, Dorchen Leidholdt and Sanctuary for Families from appearing
as counsel in this case. This case in its various aspects has been
going on for 17 years since 1991. I had first brought Dayawathie
Rankoth to America in 1988 on a tourist visa because she was pregnant,
in order that she give birth in America to confer American citizenship
on our child. I entrusted her to Sister Bernadine Dominick, who ran a
home for unwed mothers called the Casa Vincentia in Oakland,
California. Dayawathie gave birth to Michael there on June 18, 1988.
As Dayawathie was here on a tourist visa, it was necessary to take her
back within the time allotted for her visa, so in July, 1988, I took
her back to Abu Dhabi where we had been living. On February 10, 1989,
after Dayawathie had been arrested by the police, she flew back to her
home in Bowalawatta, Kandy, Sri Lanka, leaving Michael with me. I
later made two trips to Sri Lanka to get her out. The first trip in
August 1989 I could not get her out because the civil war had reached
its peak and all government offices were closed. She became pregnant
with out second child, George, on that trip. In November 1989 I made
another trip to Sri Lanka and this time I was able to get her out and
I brought her to Fujairah, United Arab Emirates, where we were living.
As she was pregnant again, I later obtained another tourist visa for
her so that she could give birth to our next child in America too.
14. In 1991, we were living in my mother's house at 917 Old Trents
Ferry Road in Lynchburg, Virginia when on or about June 19, 1991, I
brought Dayawathie Rankoth who was four months pregnant and our
children Michael and George by car to Jamaica Queens. I had business
to take care of the following morning, so I arranged for them to stay
one night in a hotel and then I planned to take them the following
morning back to my mother's house in Lynchburg, Virginia where we had
been staying up until this time. Unfortunately, as I had business to
take care of, I was one hour late the following morning to come back
to pick them up. Upon arrival I was told that they had been waiting
outside for me and had just stepped back inside. I was told that they
were just coming down the steps and to wait outside as they would be
down in a minute. I waited in my car with the motor running because it
was a no parking area and I did not want to get a ticket.
15. So I waited and waited and waited. I was told by another resident
that Dayawathie and the children had been stopped on their way out the
door taken into a office by a Miss Bivins, who had locked the door.
The other residents were concerned about this because they did not
know what was going on.
16. I continued to wait outside the building for more than 24 hours. I
finally found a legal parking space on the same block and slept in my
car. They never came out. Finally, the following afternoon, another
resident called out the window that they had been taken out the back
door and put in a closed van the previous evening and taken to an
unknown location.
17. I spent the next four years looking for them, checking with every
possible agency and even walking the streets of New York City trying
to locate them. Shortly after their disappearance, I received a
telegram from Sebastian Ike of the Child Welfare Agency in New York
City who informed me that the CWA was investigating them and was
considering starting removal proceedings to take the children away
from the mother. However, the CWA had lost track of them too and were
unable to find them just as I had been.
18. Just a day or two before their disappearance, I had started a
proceeding in New York Family Court because I feared that something
like this might happen. There had been prior court proceedings in
Queens and in Lynchburg, Virginia which had been abandoned. There were
several court hearings in New York Family Court over the next more
than one year until October 1992. Each time the judge ordered the
whereabouts of the children revealed to him. Each time the agency
reported that they were unable to locate the children or that the
�social worker� had refused to reveal their whereabouts. That �social
worker� has since been revealed as Sister Theresa Courtney of
Sanctuary for Families, who has never been, as far as I am aware, an
official of the City of New York.
19. Since Dayawathie had been four months pregnant at the time of her
disappearance, I knew the due date of the delivery of her child,
Anusha, the same child who is the subject of the proceeding here. At
the time of the due date, I started calling every hospital in New York
City that delivers babies to see if this child had been born. Finally,
I hit pay dirt because St. Vincent's Hospital informed me that the
child had been born there. I have since been wondering why they chose
St. Vincent's Hospital since I now know that Dayawathie never lived
anywhere near that hospital.
20. I went to St. Vincent's Hospital on the pretext of wanting to pay
the hospital bill for the birth of the baby. They gave me the bill
which showed the address of the mother to be PO Box 413, Times Square
Station, New York NY. I went to that post office and filed a Freedom
of Information Request for the identity of the holder of that PO Box.
This revealed that the holder of this PO Box was Sanctuary for
Families.
21. I found out that Sanctuary for Families was located in a church on
the SW corner of 46th Street and Eighth Avenue in New York City. I
staked out the church for a while to see if I could see Dayawathie and
the children going in or out of there. When that failed, I called the
New York City Police and complained that my children and their mother
had been kidnapped and were being held prisoner inside. The staff of
Sanctuary for Families treated this as a joke. The police searched the
place but of course could not find the children.
22. I attempted to file a writ of habeas corpus in New York Supreme
Court but the judge refused to sign the writ because I could not
provide an actual address for the children. Finally, in 1992 I filed a
suit in Federal Court in Brooklyn against Sanctuary for Families
alleging a conspiracy to kidnap all of my children. The case was Sloan
vs. Pattison, 92 Civil 2388 (EDNY) (RJD). Sanctuary for Families
appeared and answered through Lawrence Kamin, Esq. of the prestigious
law firm of Willkie, Farr & Gallagher. They filed an answer which
essentially denied any knowledge of the whereabouts of the children
and their mother. The case was eventually dismissed
http://www.anusha.com/judgego.htm .
23. Finally, in April, 1995, I retained Denise Grey, an investigator
who specializes in finding children who have been given away for
adoption. Amazingly, she found the children right away. They were
living in the South Bronx, at 905 Tinton Avenue.
24. I went to that address and Dayawathie immediately invited me to
come in to live with her. She introduced me to Anusha who had been
born in the four years that I had been unable to locate the children.
Anusha was now three and a half years old and had been told that her
father was dead.
25. The children were very surprised to meet their father especially
since they had been told that I was dead. George fainted. Dayawathie
told me all about Sister Theresa Courtney, about how she had led her
out the back door when I had been waiting out the front door. In the
intervening four years, Dayawathie had been living in a variety of
safe houses, especially one on Allerton Avenue in the North Bronx.
26. I had thought that after all the trouble they had gone to hide the
mother and the children from both me and the Child Welfare
Administration, that at least they were being kept in a good place. I
was proven wrong. They were living in the most horrifying squalor
imaginable. There were a million cockroaches on the walls, so many
that you could not really see the walls. Their best friends were
prostitutes and crack addicts named Julie, Jean and One-Legged Brenda
(who had lost her leg due to drug addiction), who lived upstairs. They
regularly did business with a loan shark named Panama.
27. The children told me all about Sister Theresa Courtney, who
visited them regularly and whom they very much disliked. It was
obvious that Sister Theresa Courtney knew the horrifying conditions
under which the children were living and was doing nothing about it.
28. I spent two weeks cleaning up Dayawathie's apartment while living
there. Then, I had to go back to California. Dayawathie asked me to
take the two boys, Michael and George, with me because they were wild
and out of control. She wanted to keep Anusha with her. Naturally, I
agreed to take the boys with me. I gave Dayawathie five hundred
dollars and she bought the boys new sets of clothing for their trip to
California. However, Dayawathie said to me repeatedly �Don't tell
Theresa�. She said that Theresa would be very angry if she found out
that the kids were in California. Naturally, I promised not to tell
Theresa.
29. We flew to California and I lived in San Francisco with my two
sons Michael and George for one month. We lived at 2550 Webster
Street, the Bourn Mansion, a famous building where I was helping the
owner with her many court cases. Just as Dayawathie had said, the boys
were far more difficult and unruly than I had imagined. They often
fought with each other. The owner of the Bourn Mansion wanted to kick
us out because they tore up her garden in her back yard. A bigger
problem was that Michael refused to go to school. Finally, I took them
over to Alameda where their half-sister Jessica was attending the
Haight School. I enrolled them in the same school as Jessica was
attending.
30. I was considering moving to the East Bay, where I had attended the
University of California at Berkeley. We spent a few nights in
Oakland. However, the owner of the Bourn Mansion, Arden Van Upp,
called me back to help her with some of her legal work. Just when I
got there, Dayawathie called to inform me that Theresa Courtney had
found out that the children were in California. The way she had found
out was that the Haight School, where I had enrolled the boys, had
called the school in the Bronx which the boys had previously attended.
However, that school instead of calling Dayawathie had called Theresa
Courtney. Dayawathie was upset at this development and said that she
was thinking of coming to California.
31. Just as we were talking on the telephone, there was a knock on the
door. I answered the door and it was the police, who arrested me. I
could not understand what had happened. I had spoken to Dayawathie on
the phone every day since I had brought the boys to California. In
fact I was talking on the phone to her at the very moment the police
came knocking on the door. She was just explaining that the school in
the Bronx where Dayawathie was living had informed Theresa that the
two boys were in California and were attending school there. This had
happened because the school in Alameda, California had contacted the
school in the Bronx asking them for a transfer of the student records.
The school in the Bronx had apparently breached student confidentially
by telling Theresa Courtney that the boys were in California.
Dayawathie of course knew that the boys were in California but had
kept this information secret from Theresa. Now, Theresa had gone to
her lawyer in Manhattan and had a judge in Manhattan issue a writ of
habeas corpus to bring the boys back to New York.
32. The question was how a judge in Manhattan was able to do this when
Dayawathie and the children were living in the Bronx. The answer is
that they gave a FAKE ADDRESS. As Dayawathie explained it to me, the
attorney for Sanctuary for Families was a personal friend with a judge
in Manhattan. She had called the judge at home at night. The judge
agreed to issue the order provided that the case was filed in
Manhattan. Now, in order to get jurisdiction in Manhattan they created
a fake address. The address was 410 West 40th Street, New York NY
10036. Dayawathie however lived at 905 Tinton Avenue, Bronx NY. She
had never lived in Manhattan at that or any other address. I later
went to 410 West 40th Street. You can see that address if you ever
take a bus to New York City because the bus goes right in front of
that address just before it enters Port Authority Bus Terminal. There
is a soup kitchen there operated by a church. I went to the soup
kitchen and showed the pastor a picture of Dayawathie and the
children. He said that he had never seen them before in his life. He
said that Sanctuary for Families had rented an apartment upstairs
during the period in question, but nobody had ever lived there and he
was completely certain that Dayawathie had never been there.
33. In California they have a law which does not exist in New York or
in any other state as far as I am aware that a person can be arrested
and held �pending investigation�, without any charges being brought.
Bobby Fischer was notoriously held under that law and wrote a book
about it. That is how they arrested me. I was never taken to court. I
never saw a judge. They put me in jail in San Francisco and then
transferred me to Santa Rita County Jail near Oakland. During this
time, my two boys, Michael and George, were extradited to New York.
34. I was released in June with no charges ever being brought. As far
as I am aware, there is no record of me even being in jail in
California. After I got out, I flew back to New York. However,
Dayawathie and the children had disappeared again. Sister Theresa
Courtney had moved them out of 905 Tinton Avenue and taken them to
parts unknown.
35. A writ of habeas corpus should not have been issued by the New
York Family Court because of no jurisdiction. Dayawathie had never
been awarded legal custody of the children by any court. The previous
case in 1991 had been dismissed with no final order entered because
Dayawathie had disappeared with the children when Sister Theresa
Courtney had hidden them. Michael had been born in Oakland, California
so in no way did New York have jurisdiction. Nevertheless, the boys
were extradited to New York while I was still in jail. I was released
from jail in California. No charge was ever brought against me. I was
never even taken before a judge. However, by the time I got out the
boys were gone.
36. During the two weeks that I had been living with Dayawathie at 905
Tinton Avenue, she had become pregnant with our fourth child. Upon
finding out that Dayawathie was pregnant with our fourth child, Sister
Theresa Courtney had arranged for Dayawathie to have an abortion. As
Dayawathie later has explained it, Theresa said that since she was a
nun in the Roman Catholic Church, she could not personally take
Dayawathie to the abortion clinic. Therefore, she arranged for a
co-worker to take Dayawathie to the abortion clinic. The abortion was
performed on July 7, 1995. I know this date because I later saw
documents, including an appointment letter and a bill providing this
date, as the date of the abortion.
37. Thus, after I got out of jail after having been arrested by an
illegal order, my sons had been extradited to New York and my unborn
baby had been aborted. When I went to New York to try to locate
Dayawathie again, Theresa had moved her out of the apartment at 905
Tinton Avenue and Dayawathie had disappeared to parts unknown. The
case under which the writ of habeas corpus had been issued, No.
V-4534/95, was dismissed. I tried to reopen it, without success.
38. Almost immediately after the abortion of July 7, 1995, Dayawathie
became pregnant by a passing stranger. As a result, Geeta Rankoth, her
fourth child, was born June 9, 1996. Dayawathie believes that the
father was named Kamal and that he was from Bangladesh but I have
asked around in the Bangladesh community and there is no such person
from Bangladesh in New York. The result is that instead of having a
child with me as the father, Dayawathie had a child by an unknown
father. Geeta by the way is a wonderful child and I often refer to her
as my step-daughter.
39. The problem Dorchen Leidholdt now has is that between 1991 and
1995 Dayawathie could not contact me because she did not know where I
was and she could not yet speak English and I did not know where she
was. However, now, Dayawathie knew where I was and soon she called me
and gave me her new address, which was on Ft. Hamilton Parkway near
Prospect Park. This was a facility operated by Sanctuary for Families.
In July 1996, I went there with my other daughter Jessica, aged 7, and
we met Dayawathie, Anusha and the newborn baby Geeta near the subway
station and spent the day in Manhattan together. I then went with
Jessica to play in the US Open Chess Championship in Alexandria,
Virginia. When we got back in New York two weeks later, Dayawathie and
the four children had been moved out of the Ft. Hamilton Parkway
facility. Apparently, Sister Theresa Courtney had found out that we
had met and had moved Dayawathie to another facility.
40. In February, 1997, Dayawathie called me again. She had just been
given a new apartment on 1581 Park Avenue, New York NY This is in the
Johnson Housing Project at 113th Street and Lexington.. She asked me
to move in with her, which I did. We lived together there for several
months.
41. Unfortunately, soon thereafter some of the denizens she had left
behind in the Bronx named Jean, Julie and One-Legged Brenda found her.
By then they had been evicted from their own apartments in the same
building, 905 Tinton Avenue, and now they were staying with friends in
the project across Lexington Avenue. Soon, they moved into
Dayawathie's apartment. Before long, we had Jean, Julie, Jeans
daughter, One-legged Brenda and new comers Brenda Morales and Jimmy
all living with me, Dayawathie and the four children in the same two
bedroom apartment. As Princess Diana later famously commented, �It was
a bit crowded�.
42. I tried to convince Dayawathie to lock these people out, but she
kept letting them in. They usually came home at about 2 AM. We later
found out that Brenda Morales and Jimmy were HIV Positive. This is the
reason they could not find any place else to live. Brenda Morales was
a professional thief. She would take my children, Anusha and George,
to stores and use them as decoys so that she could steal stuff. If she
was caught, the police would be reluctant to arrest her because of the
two children with her. Dayawathie knew about this but would do nothing
to stop it.
43. Julie, Jean and One-Legged Brenda were five-dollar prostitutes,
especially One-Legged Brenda. She lost her leg to drug addiction. They
often smoked Crack. One-Legged Brenda gave birth to a baby and social
services immediately took the baby away from the crack-addicted
mother. A few days after One-Legged Brenda got back from delivering
the baby, I went to sleep in the apartment with nobody but me,
Dayawathie and the four children there. I was hoping to have a night
of peace. However, I woke up in the middle of the night to find that
One-Legged Brenda had crawled into bed with me. Some men would be
happy to find a woman in bed with them but I certainly was not happy,
especially since I knew that One- Legged Brenda was HIV Positive and a
crack addict. Dayawathie had opened the door and let Jean, Julie,
Jean's daughter and One-Legged Bredna into the apartment in the
middle of the night. Jean, Julie and Jean's daughter had taken over
the beds in which my children, Michael, George and Anusha were
sleeping. They had pushed Michael, George and Anusha onto the floor
and were sleeping in their beds while my children were now sleeping on
the floor.
44. Finally, I had to act, so I secretly called 911. I reported that
drug addicts and prostitutes had pushed their way into our apartment,
which was true. The police arrived and I opened the door. They found
Jean, Julie, Jean's daughter and One-Legged Brenda all asleep. They
woke them up and searched the place but could not find any crack. All
the crack vials had been thrown down the garbage chute.
45. This was about 5:00 AM. While the police were doing this,
Dayawathie called Sister Theresa Courtney and woke her up. Dayawathie
did not tell Sister Threresa Courtney anything about Jean, Julie,
Jean's Daughter and One-Legged Brenda. Instead, she complained that I
was in the apartment (not mentioning that by then I had been living
there for four months). The end result was that the police took away
my keys to the apartment and told me to leave, which I did. Jean,
Julie, Jean's daughter and One-Legged Brenda were still allowed to
stay there. (I believe that Jimmy and Brenda Morales were not present
at the time of this incident.)
46. I was at that time working for a real estate holding company at 24
Sixth Avenue in Brooklyn. Twice, my other daughter, Jessica, and her
mother, Renuka, flew from Alameda California to visit us and each time
they stayed with Dayawathie and my other three children at 1581 Park
Avenue in New York. Dorchen Leidholdt found out about this and
approached Renuka and asked for her help in getting me arrested, but
Renuka refused to cooperate and instead went back to California.
47. During this time, Dayawathie was calling me 20 times a day at work
asking for stuff and this was disturbing my boss as work and made his
wife angry. I lost that job and I went to live with my friend from
Afghanistan, Sayed Durali Shah, who lives in Far Rockaway. Dayawathie
called me many times asking me to come back there, but I refused to
go. One night at about 7:00 PM Dayawathie called to say that Anusha
was very sick and needed to be taken to the hospital. However,
Dayawathie could not take her because she needed to take care of the
other three children. Therefore, Dayawathie wanted me to come to her
home and either take Anusha to the hospital or else stay with the kids
while Dayawathie took Anusha to the hospital.
48. I was very tired. I had been working as a taxi driver for Towne
Taxi in Lawrence Long Island. I wanted to go to sleep, but in view of
the emergency I got out of bed and made the two hour trip by subway
from Far Rockaway to Spanish Harlem where Dayawathie lived.
49. When I walked in the door to Dayawathie's apartment, I was
surprised to find Michael, George and Anusha running around playing
quite happily. Anusha did not look sick at all. Only one second later
two police officers came out the bedroom and arrested me. It had all
been a trap set by the police. The arresting officer was Carmen
Bonilla. She had sat by Dayawathie coaching her on exactly what to
say. This entire story about how Anusha was sick and needed to be
taken to the hospital was a pure fabrication. Dorchen Leidholdt was
involved in this, because as soon as she had arrested me Carmen
Bonilla called Dorchen Leidholdt on the phone to tell her the good
news. I was taken to jail.
50. They had made up a purely invented story that I had come to the
apartment with my 16-year-old girlfriend and had forced our way into
the apartment and had hit Dayawathie's head against the wall. Nothing
like that had ever occurred. Yes, there was such a girl, but she was
17, not 16, and we had been palling around for months but she was
never my girlfriend. Dayawathie had never met her. She had never been
to that apartment. Her name was Irina Novikova. She was from St.
Petersberg, Russia and I was giving her lessons in shogi, or Japanese
chess, of which I am a top player. She had converted to Hassidim and
lived in the Machon Chana in Crown Heights, Brooklyn, but every
Saturday she would sneak out to come to see me. Dayawathie had never
met her but had heard about her and was jealous and thus had invented
this entire story.
51. I called Irina Novikova from the jail and asked her to come to
court to testify in my defense. She said she would come, but did not
show up. Soon thereafter she went back to Russia and I never saw her
again until she returned to America four years later,
52. When the date came for the court hearing, Dorchen Leidholdt and
Dayawathie did not show up. In that event, they were supposed to
release me but instead they made a new bogus charge against me and put
me back in. Another six days passed. I was brought from the jail to
the courthouse. I sat all day in the waiting room behind the
courtroom. At 5:00 PM my court appointed lawyer came back to see me
and told me that Judge Ross had gone for the day. Therefore, there
would be no court hearing and I would be released as the case was
dismissed. By not allowing me to come before him in open court Judge
Ross had cheated me out of my chance to complain that I had been held
in jail for 12 days for no reason at all. I attach a copy of a letter
from Dorchen Leidholdt saying that she was dropping the case because
she could not prove it �by a preponderance of the evidence�. No
mention of �beyond reasonable doubt�. The letter was dated June 20 and
had been delivered by hand. Nevertheless, Judge Ross had kept me in
jail until June 23 even though he knew that the case was being
dismissed.
53. I went to the office of the District Attorney several times
demanding that Dorchen Leidholdt be criminally prosecuted for bringing
this false case. However, the ADA, Eileen Chiu, said that she could do
nothing because again Dayawathie had disappeared. Dorchen Leidholdt
wrote a letter saying that she no longer represented Dayawathie and
did not know where she was. This was another lie. Dorchen had moved
Dayawathie to a facility Dorchen operated in Queens.
54. Before long, Dayawathie started calling me again. She was living
in a facility operated by Sister Theresa Courtney and Dorchen
Leidholdt at 166th Street and Hillside Avenue in Queens. She wanted me
to come there but I refused to go. She wanted me to buy presents for
the kids. Finally, I agreed to meet her at the big shopping mall on
33rd Street and Herald Square on Sixth Avenue in Manhattan. We met
many times there and I would treat the kids. There were no court
orders or custody orders because everything had been dissolved every
time she disappeared. Still, I was afraid to come to her residence.
55. In early 1998 she got a new apartment at 40-08 12th Street, Long
Island City, Queens, New York in the Queensbridge Housing Project. She
did not like the place, much preferring her old apartment in
Manhattan. However, she finally asked me to come live there. The deal
we made was that Sister Theresa Courtney and Dorchen Leidholdt only
came to see her on Saturday or Sunday and only came during the daytime
because they were afraid of the Black people at night. Therefore, I
would never come at those times. I would maintain my own residence. If
Dorchen Leidholdt or Theresa Courtney ever came at an unusual time
when they were not expected, I would hide in a closet or in the
stairwell on a higher floor and leave the building as soon as they
entered the apartment. Dayawathie gave me keys to her apartment and to
the building and I could pretty much come and go as I pleased as long
as I followed those rules.
56. This was the deal for the past seven years, from 1998 to 2005. As
long as Dorchen Leidholdt and Theresa Courtney did not know about it,
I could even bring friends over. My other daughters, Shamema and
Jessica, have visited there. Jessica even lived there for a while. I
have ried and my wife Kayo and our daughter Sandra have been
frequent visitors in the home. Rusudan Goletiani, who is the US Womans
Chess Champion, has visited me there, as has my friend io
Sacripante for whom I worked when I was living in Japan in 1984. I
have also made friends with some of the neighbors. Thus, I have lots
of witnesses who could testify that I was freely coming and going in
the home for the past seven years. There has been no problem, no
arrests, no custody cases, for these seven years.
57. In 1999, my other daughter, Jessica, came from California to live
with me. However, she strongly preferred to stay with her
half-brothers and sisters, Michael, George and Anusha, so she lived in
Dayawathie's apartment at 40-08 12th Street, Long Island City. I
enrolled Jessica in school there, the same school that Michael and
George were attending. However, Dorchen Leidholdt and Sister Theresa
Courtney found out about this, went to the school and objected. As a
result, Jessica was not allowed to attend school there. I complained
to the Board of Education, to no avail. Finally I had to send Jessica
back to California.
58. There has been a big problem with Surinder Singh a/k/a Kala. He
was a homeless bum that Dayawathie had met while she was living in the
homeless shelter at 166th Street and Hillside Avenue. He followed her
to her new apartment at 40-08 12th Street. Dayawathie says that at
first he was nice. However, later, he was drunk all the time. He would
beat and abuse her. She would call 911. The police would come but he
would run away. Sometimes he would hide on the roof of the building
and come back down after the police left. Sometimes the police would
even catch him in the apartment but would not arrest him even though
he was obviously drunk and abusive. He was eventually arrested six
times in her apartment but then the judge would let him out after just
a few hours and he would come right back. Dayawathie got a dozen
orders of protection against him but he just ignored them.
59. Finally, the New York City Housing Department started an eviction
proceeding against Dayawathie for letting Surinder Singh into the
apartment where he would cause a constant commotion. Dayawathie got
Dorchen Leidholdt to defend her in this court case. Dorchen settled
the case with an order in which Dayawathie agreed not to allow
Surinder Singh OR Sam Sloan into her apartment, or otherwise she would
forfeit the apartment. Dorchen Leidholdt added my name to the case,
even though the New York City Housing Department had never heard of
me. They did not even know my name because the police had never been
called about me and there had never been any trouble about me.
60. This court order has made Dayawathie fearful of allowing me to
stay in the apartment. I have never spent the night there since. My
visits have been brief. Meanwhile, Kala has disappeared. I suspect
that he was finally deported back to India after 9/11.
61. It is my absence that has allowed the two drug dealers from Tioga,
Pennsylvania to move in. They moved in full time in about February,
2005. Before that, they were just coming and going from Tioga to New
York. I know where they are from because one time Dayawathie went to
visit them in Tioga. She had me take care of the children while she
was gone and gave me the number there which she told me to call in
case of emergency, but she insisted that I never reveal that I had the
number.
61. From all of the above, it should be obvious that Jill Zuccardy,
Dorchen Leidholdt and Sanctuary for Families are disqualified from
appearing as counsel in this case. They have their own agenda which in
in conflict with the best interests of the mother and the children.
Rather than prove any case they might have against me, they repeatedly
uproot the children and disappear with them. They have had me arrested
three times but each time they have not come to court on the court
date and instead have disappeared with the children again. In 1997,
Dorchen Leidholdt wrote letters saying that she no longer represents
Dayawathie Rankoth and does not know where she is, but Dayawathie says
that there has never been even one day when Dorchen did not know where
she lives because she has been living in a facility provided by
Dorchen Leidholdt. Jill Zuccardy is a young lawyer who just graduated
from law school in 2005 and this must be one of his first cases. He
works for Sanctuary for Families and obviously does not know what he
is getting into.
62. Finally, Jill Zuccardy, Dorchen Leidholdt and Sanctuary for
Families tried to have me arrested again when this case was in court
on October 6, 2005. This is their tactic. They cannot prove their case
in court, so they want to win by having their opponent arrested and
then disappearing with the children so that the father cannot find
them again. This sort of behavior requires more than they be merely
disqualified from this case. They should be disbarred from the
practice of law.
63. Dorchen Leidholdt is a lesbian lunatic and a sick demented woman.
She founded an organization called �Victims of Pornography�. While
constantly railing in the press against pornography and organizing the
street demonstrations one sees from time to time, her writings are
actually pornographic. For example, her often cited statement that 25%
of all female children are sexually molested by their own fathers is
itself pornographic. For this reason, the statements by Dorchen
Leidholdt are often published in pornographic literature such as
Hustler Magazine. Hustler also publishes revealing pictures of Dorchen
Leidholdt taken when she was younger.
64. However, I do need to tell you about this, because you can read it
yourself. Attached hereto is a copy of an article Dorchen Leidholdt
wrote entitled, �When Women Defend Pornography�, which is found in the
book �The Sexual Liberals and the Attack on Feminism� by Dorchen
Leidholdt and Janice G. Raymond. This book is filled with essays by
militant lesbians, some of them quite famous. Anybody reading this
essay will immediately realize that the author is seriously ill and
emotionally disturbed.
65. Dorschen Leidholdt is the legal director for Sanctuary for
Families, She is the boss of Jill Zuccardy who is a new hire having
just graduated from Columbia University Law School in 2005. Dorchen
has founded numerous groups, one of which is the �Coalition Against
the International Trafficking of Women�. She uses my children and
their mother as the poster children for her organization. This is
obviously based on the fact that I brought the mother, Dayawathie
Rankoth, from Sri Lanka to America twice to give birth to my children.
66. Dorchen Leidholdt uses my children to collect charitable
contributions. She has established various 501(c)(3) corporations. In
short, she uses my children to make money. Wealthy people can get tax
deductions by donating to the various organizations which Dorchen
Leidholdt has founded. Dayawathie Rankoth thinks that Dortchen
Leidholdt is a nice lady her gives her money all the time but that is
because she fails to realize that what is really going on is Dorchen
Leidholdt is using her to make money. This is obviously a conflict of
interest.
67. Dorchen Leidholdt has had me arrested three times. In May and June
1995, I was held in jail mostly in the Alameda County Jail in Santa
Rita for 42 days on a charge of kidnapping. However, I was never
brought before a judge in court. California allows a person to be held
�Pending investigation�. Meanwhile Dorchen Leidholdt had my two sons,
Michael and George, extradited to New York, which is why they are here
now.
68. She had me arrested twice again in 1997. I was living in Far
Rockaway Queens and driving a taxi for Towne Taxi in nearby Lawrence,
Long Island. Dorchen Leidholdt had Dayawathie call me and tell me that
Anusha was seriously ill and needed to be taken to the hospital and I
needed to come to her house right away. What I did not realize was
that Dorchen Leidholdt had taken out an order of protection against me
which I had never been served with so I did not know about. When I
appeared at the apartment to take Anusha to the hospital for this
serious illness she was supposedly suffering from, two police officers
were waiting to arrest me in a trap set by Dorchen Leidholdt.
69. Dorchen Liedholdt is doing the same thing here again. Here we have
an order of protection prohibiting me from seeing any of my children
including my eldest son Michael. However, Michael is not in the home.
He has been arrested and is in mental hospital. His case worker is
Nicole Valasko. She had called me and advises me that Michael should
not be returned to the home of Dayawathie Rankoth. Michael should live
with me, her father, she says. Two psychiatrists, Dr Arya and Dr.
Attila Polonyi, have made the same recommendation. I am sure that, if
asked, they would recommend that all three of my children be removed
from that home, especially since Dayawathie has had two drug dealers
living there. Yet, the court does not know about this, because of the
misconduct by Dorchen Leidholdt and her subordinate Jill Zuccardy. I
was not even allowed to send Christmas presents to my children.
70. From all this, there is obviously a major conflict of interest
between Dorchen Leidholdt and her subordinate Jill Zuccardy and
Dayawathie Rankoth and the three children. This struggle has been
going on for 17 years since 1991. Dorchen Leidholdt and Jill Zuccardy
have their own interests including an interest in not being arrested
and charged with kidnapping for bringing my children from San
Francisco, California where they were living to New York. It is not
proper for them to be allowed to represent a party to this case.
WHEREFORE, for all of the reasons set forth above, Jill Zuccardy,
Dorchen Leidholdt and Sanctuary for Families from appearing as counsel
in this case.
___________________________
Samuel H.
Sloan
1664 Davidson
Avenue, Apt. 1B
Bronx NY
10453-7877
[email protected]
917-507-7226
347-869-2465
Sworn to before me this 20th Day
of May, 2008
_______________________________
NOTARY PUBLIC
VERIFICATION
I, the undersigned, the petitioner named in the foregoing petition,
being duly sworn, says:
I have read the foregoing petition subscribed by me and know the
contents thereof and the same is true of my own knowledge, except as
to those matters herein stated to be alleged upon information and
belief and as to those matters I believe it to be true.
_________________________
Signature of
Petitioner
On the 20th Day of May, 2008 before me personally came Samuel Sloan to
me known to be the person described herein and who executed the
foregoing instrument. Such person duly swore to such instrument before
me and duly acknowledged that he executed the same.
_____________________________
NOTARY PUBLIC
|
| |
Date: 19 May 2008 21:05:21
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: SECOND DEPARTMENT
------------------------------------------X
No. 2008-02071
DAYAWATHIE RANKOTH,
Docket No. O-18182-05
Petitioner - Respondent
Queens County Family Court
- against -
MOTION TO DISQUALIFY
SAMUEL SLOAN, Jill
M. Zuccardy and
Sanctuary for Families, Inc.
, Respondent-Appellant. from
appearing as counsel
------------------------------------------X
in this case
AFFIDAVIT IN SUPPORT OF MOTION TO DISQUALIFY Jill M. Zuccardy and
Sanctuary for Families, Inc. from appearing as counsel in this case:
Samuel H. Sloan, being duly sworn, deposes and says:
1. I am the Respondent-Appellant in the above entitled case. I make
this motion to disqualify Jill M. Zuccardy and Sanctuary for Families,
Inc. from appearing as counsel in this case.
2. JILL M. ZUCCARDY begins her affirmation to dismiss my appeal with
the following paragraph:
"1. I am a pro bono attorney associated with Sanctuary for Families'
Center for Battered Women's Legal Services."
3. This statement alone is unfair and prejudicial. It implies that
Dayawathie Rankoth, the Petitioner - Respondent herein, is a "battered
woman". In reality this is not the case. There is no allegation, much
less evidence or proof, that Dayawathie Rankoth has ever been
battered, abused or mistreated in any way.
4. In addition, these statements have the effect of threatening and
intimidating the judges of this and other courts. If the judges decide
a case contrary to the wishes of Dorchen Leidholdt, she will go to the
newspapers and complain that the courts are failing to protect
battered women and that the courts themselves are abusers of women.
She often does exactly this. Dorchen Leidholdt is managing director,
founder and CEO of Sanctuary for Families. She had to make a great
personal sacrifice to do this, by giving up her career as a child
pornography gadfly.
5. You heard that exactly right. Attached hereto is a feature article
about Dorchen Leiodholdt as published in Hustler Magazine. Dorchen
Leidholdt first became famous as a target of the Meese Commission on
Child Pornography.
6. In an article published in May 2006 in the New York Law Journal,
Dorschen Leidholdt was quoted as saying that all of the judges of the
Queens Family Court are bad except that there is one good judge. His
name was Judge Modica. Judge Modica happens to be the judge on this
case.
7. Jill M. Zuccardy works for Dorchen Leidholdt. She should not be
allowed to appear in this case.
.
.8. Sanctuary for Families is not a registered and licensed law firm.
The last time this case was before this court, Dorchen Leidholdt had
hired Paul, Weiss, Rifkind, Wharton & Garrisonto appear in this case.
It is apparent that Paul Weiss has seen the light and does not want to
appear any more. Probably this was pro bono work because they thought
they were representing a "battered woman". Having found out that there
is no battered woman involved in this case, they have discharged their
duties and no longer want to be involved.
.
9. Attached hereto as an exhibit is the Form 990 for Sanctuary for
Families proving that Dorchen Leidholdt is the managing director of
Sanctuary for Families, Inc. Attached hereto as another exhibit is a
non-pornographic feature article about Dorchen Leidholdt from Hustler
Magazine. Attached hereto as a third exhibit is the cover of a book by
Dorechen Leidholdt entitled "The Sexual Liberals and the Attack on
Feminism".
.
.10. Dorchen is a notorious lesbian activist. She should not be
allowed to have contact with anybodies children, and especially not
with my children. I can only wonder what the orientation of Jill
Zuccardy is, since she works for Dorchen Leidholdt. My assigned
counsel in the prior appeal to this court, Pauline Brandt, told me
that she is quite familiar with Dorchen Leidholdt and Sanctuary for
Families, having opposed them in many cases in the Family Court and
they are "crusaders", in the words of Pasuline Brandt. They are not
concerned with the mother and her children in the case before the
courts. They want to make a political and social point. For example,
Dorschen Leidholdt campaigns against the "Mail Order Bride Industry".
That may explain her interest in this case as she is regarding
Dayawathie Rankoth, who is from Sri Lanka, as some sort of mail order
bride.
11. The duty of any attorney is to her client. However, the priy
duty of Jill Zuccardy is to her boss, Dorschn Leidholdt. Therefore
Jill Zuccardy should be disqualified from appearing in this case.
.
.12. This is not just a minor point. This is the whole case. Dorchen
Leidholdt has been attacking me amd my family for 17 years since June
1991. If Dorchen Leidholdt and her organization Sanctuary for Families
Inc. and their employee Jill Zuccardy is disqualified from this case,
this case will be over and I can get my children and their mother
back. The mother, Dayawathie Rankoth, is mortally afraid of Dorchen
Leidholdt, which is the reason why I know so much about her.
.
.13, I make this affidavit in support of a motion to disqualify Jill
Zuccardy, Dorchen Leidholdt and Sanctuary for Families from appearing
as counsel in this case. This case in its various aspects has been
going on for 17 years since 1991. I had first brought Dayawathie
Rankoth to America in 1988 on a tourist visa because she was pregnant,
in order that she give birth in America to confer American citizenship
on our child. I entrusted her to Sister Bernadine Dominick, who ran a
home for unwed mothers called the Casa Vincentia in Oakland,
California. Dayawathie gave birth to Michael there on June 18, 1988.
As Dayawathie was here on a tourist visa, it was necessary to take her
back within the time allotted for her visa, so in July, 1988, I took
her back to Abu Dhabi where we had been living. On February 10, 1989,
after she had been arrested by the police, she flew back to her home
in Bowalawatta, Kandy, Sri Lanka, leaving Michael with me. I later
made two trips to Sri Lanka to get her out. The first trip in August
1989 I could not get her out because the civil war had reached its
peak and all government offices were closed. She became pregnant with
out second child, George, on that trip. In November 1989 I made
another trip to Sri Lanka and this time I was able to get her out and
I brought her to Fujairah, United Arab Emirates, where we were living.
As she was pregnant again, I later obtained another tourist visa for
her so that she could give birth to our next child in America too.
14. In 1991, we were living in my mother's house at 917 Old Trents
Ferry Road in Lynchburg, Virginia when on or about June 19, 1991, I
brought Dayawathie Rankoth who was four months pregnant and our
children Michael and George by car to Jamaica Queens. I had business
to take care of the following morning, so I arranged for them to stay
one night in a hotel and then I planned to take them the following
morning back to my mother?fs house in Lynchburg, Virginia where we had
been staying up until this time. Unfortunately, as I had business to
take care of, I was one hour late the following morning to come back
to pick them up. Upon arrival I was told that they had been waiting
outside for me and had just stepped back inside. I was told that they
were just coming down the steps and to wait outside as they would be
down in a minute.
15. So I waited and waited and waited. I was told by another resident
that Dayawathie and the children had been stopped on their way out the
door taken into a office by a Miss Bivins, who had locked the door.
The other residents were concerned about this because they did not
know what was going on.
16. I continued to wait outside the building for more than 24 hours. I
slept in my car. They never came out. Finally, the following
afternoon, another resident called out the window that they had been
taken out the back door and put in a closed van the previous evening
and taken to an unknown location.
17. I spent the next four years looking for them, checking with every
possible agency and even walking the streets of New York City trying
to locate them. Shortly after their disappearance, I received a
telegram from Sebastian Ike of the Child Welfare Agency in New York
City who informed me that the CWA was investigating them and was
considering starting removal proceedings to take the children away
from the mother. However, the CWA had lost track of them too and were
unable to find them just as I had been.
18. Just a day or two before their disappearance, I had started a
proceeding in New York Family Court because I feared that something
like this might happen. There had been prior proceedings in Queens and
in Lynchburg, Virginia which had been abandoned. There were several
court hearings in New York Family Court over more than one year until
October 1992. Each time the judge ordered the whereabouts of the
children revealed to him. Each time the agency reported that they were
unable to locate the children or that the ?gsocial worker?h had
refused to reveal their whereabouts. That ?gsocial worker?h has since
been revealed as Sister Theresa Courtney of Sanctuary for Families,
who has never been, as far as I am aware, an official of the City of
New York.
19. Since Dayawathie had been four months pregnant at the time of her
disappearance, I knew the due date of the delivery of her child,
Anusha, the same child who is the subject of the proceeding here. At
the time of the due date, I started calling every hospital in New York
City that delivers babies to see if this child had been born. Finally,
I hit pay dirt because St. Vincent?fs Hospital informed me that the
child had been born there. I have since been wondering why they chose
St. Vincent?fs Hospital since I now know that Dayawathie never lived
anywhere near that hospital.
20. I went to St. Vincent's Hospital on the pretext of wanting to pay
the hospital bill for the birth of the baby. They gave me the bill
which showed the address of the mother to be PO Box 413, Times Square
Station, New York NY. I went to that post office and filed a Freedom
of Information Request for the identity of the holder of that PO Box.
This revealed that the holder of this PO Box was Sanctuary for
Families.
21. I found out that Sanctuary for Families was located in a church on
the corner of 46th Street and Eighth Avenue in New York City. I staked
out the church for a while to see if I could see Dayawathie and the
children going in or out of there. When that failed, I called the New
York City Police and complained that my children and their mother had
been kidnapped and were being held prisoner inside. The staff of
Sanctuary for Families treated this as a joke. The police searched the
place but of course could not find the children.
22. I attempted to file a writ of habeas corpus in New York Supreme
Court but the judge refused to sign the writ because I could not
provide an actual address for the children. Finally, in 1992 I filed
a suit in Federal Court in Brooklyn against Sanctuary for Families
alleging a conspiracy to kidnap all of my children. The case was Sloan
vs. Pattison, 92 Civil 2388 (EDNY) (RJD). Sanctuary for Families
appeared and answered through Lawrence Kamin, Esq. of the prestigious
law firm of Willkie, Farr & Gallagher. They filed an answer which
essentially denied any knowledge of the whereabouts of the children
and their mother. The case was eventually dismissed
http://www.samsloan.com/judgego.htm .
23. Finally, in April, 1995, I retained Denise Grey, an investigator
who specializes in finding children who have been given away for
adoption. Amazingly, she found the children right away. They were
living in the South Bronx, at 905 Tinton Avenue.
24. I went to that address and Dayawathie immediately invited me to
come in to live with her. She introduced me to Anusha who had been
born in the four years that I had been unable to locate the children.
Anusha was now three and a half years old and had been told that her
father was dead.
25. The children were very surprised to meet their father especially
since they had been told that I was dead. George fainted. Dayawathie
told me all about Sister Theresa Courtney, about how she had led her
out the back door when I had been waiting out the front door. In the
intervening four years, Dayawathie had been living in a variety of
safe houses, especially one on Allerton Avenue in the North Bronx.
26. I had thought that after all the trouble they had gone to hide the
mother and the children from both me and the Child Welfare
Administration, that at least they were being kept in a good place. I
was proven wrong. They were living in the most horrifying squalor
imaginable. There were a million cockroaches on the walls, so many
that you could not really see the walls. Their best friends were
prostitutes and crack addicts named Julie, Jean and One-Legged Brenda,
who lived upstairs. They regularly did business with a loan shark
named Panama.
27. The children told me all about Sister Theresa Courtney, who
visited them regularly and whom they very much disliked. It was
obvious that Sister Theresa Courtney knew the horrifying conditions
under which the children were living and was doing nothing about it.
28. I spent two weeks cleaning up Dayawathie's apartment while living
there. Then, I had to go back to California. Dayawathie asked me to
take the two boys, Michael and George, with me because they were wild
and out of control. She wanted to keep Anusha with her. Naturally, I
agreed to take the boys with me. I gave Dayawathie five hundred
dollars and she bought the boys new sets of clothing for their trip to
California. However, Dayawathie said to me repeatedly ?gDon?ft tell
Theresa?h. She said that Theresa would be very angry if she found out
that the kids were in California. Naturally, I promised not to tell
Theresa.
29. We flew to California and I lived in San Francisco with my two
sons Michael and George for one month. We lived at 2550 Webster
Street, the Bourn Mansion, a famous building where I was helping the
owner with her many court cases. Just as Dayawathie had said, the boys
were far more difficult and unruly than I had imagined. They often
fought with each other. The owner of the Bourn Mansion wanted to kick
them out because they tore up her garden in her back yard. A bigger
problem was that Michael refused to go to school. Finally, I took them
over to Alameda where their half-sister Jessica was attending the
Haight School. I enrolled them in the same school.
30. I was considering moving to the East Bay, where I had attended the
University of California at Berkeley. We spent a few nights in
Oakland. However, the owner of the Bourn Mansion, Arden Van Upp,
called me back to help her with some of her legal work. Just when I
got there, Dayawathie called to inform me that Theresa Courtney had
found out that the children were in California. The way she had found
out was that the Haight School, where I had enrolled the boys, had
called the school in the Bronx which the boys had previously attended.
However, that school instead of calling Dayawathie had called Theresa
Courtney. Dayawathie was upset at this development and said that she
was thinking of coming to California.
31. Just as we were talking on the telephone, there was a knock on the
door. I answered the door and it was the police, who arrested me. I
could not understand what had happened. I had spoken to Dayawathie on
the phone every day since I had brought the boys to California. In
fact I was talking on the phone to her at the very moment the police
came knocking on the door. She was just explaining that the school in
the Bronx where Dayawathie was living had informed Theresa that the
two boys were in California and were attending school there. This had
happened because the school in Alameda, California had contacted the
school in the Bronx asking them for a transfer of the student records.
The school in the Bronx had apparently breached student confidentially
by telling Theresa Courtney that the boys were in California.
Dayawathie of course knew that the boys were in California but had
kept this information secret from Theresa. Now, Theresa had gone to
her lawyer in Manhattan and had a judge in Manhattan issue a writ of
habeas corpus to bring the boys back to New York.
32. The question was how a judge in Manhattan was able to do this when
Dayawathie and the children were living in the Bronx. The answer is
that they gave a FAKE ADDRESS. As Dayawathie explained it to me, the
attorney for Sanctuary for Families was a personal friend with a judge
in Manhattan. She had called the judge at home at night. The judge
agreed to issue the order provided that the case was filed in
Manhattan. Now, in order to get jurisdiction in Manhattan they created
a fake address. The address was 410 West 40th Street, New York NY
10036. Dayawathie however lived at 905 Tinton Avenue, Bronx NY. She
had never lived in Manhattan at that or any other address. I later
went to 410 West 40th Street. There is a soup kitchen there operated
by a church. I showed the pastor a picture of Dayawathie and the
children. He said that he had never seen them before in his life. He
said that Sanctuary for Families had rented an apartment upstairs
during the period in question, but nobody had ever lived there and he
was completely certain that Dayawathie had never been there.
33. In California they have a law which does not exist in New York or
in any other state as far as I am aware that a person can be arrested
and held ?gpending investigation?h, without any charges being brought.
That is how they arrested me. I was never taken to court. I never saw
a judge. They put me in jail in San Francisco and then transferred me
to Santa Rita County Jail near Oakland. During this time, my two boys,
Michael and George, were extradited to New York.
34. I was released in June with no charges ever being brought. As far
as I am aware, there is no record of me even being in jail in
California. After I got out, I flew back to New York. However,
Dayawathie and the children had disappeared again. Sister Theresa
Courtney had moved them out of 905 Tinton Avenue and taken them to
parts unknown.
35. A writ of habeas corpus should not have been issued by the New
York Family Court because of no jurisdiction. Dayawathie had never
been awarded legal custody of the children by any court. The previous
case in 1991 had been dismissed with no final order entered because
Dayawathie had disappeared with the children when Sister Theresa
Courtney had hidden them. Michael had been born in Oakland, California
so in no way did New York have jurisdiction. Nevertheless, the boys
were extradited to New York while I was still in jail. I was released
from jail in California. No charge was ever brought against me. I was
never even taken before a judge. However, by the time I got out the
boys were gone.
36. During the two weeks that I had been living with Dayawathie at 905
Tinton Avenue, she had become pregnant with our fourth child. Upon
finding out that Dayawathie was pregnant with our fourth child, Sister
Theresa Courtney had arranged for Dayawathie to have an abortion. As
Dayawathie later has explained it, Theresa said that since she was a
nun in the Roman Catholic Church, she could not personally take
Dayawathie to the abortion clinic. Therefore, she arranged for a
co-worker to take Dayawathie to the abortion clinic. The abortion was
performed on July 7, 1995. I know this date because I later saw
documents, including an appointment letter and a bill providing this
date, as the date of the abortion.
37. Thus, after I got out of jail after having been arrested by an
illegal order, my sons had been extradited to New York and my unborn
baby had been aborted. When I went to New York to try to locate
Dayawathie again, Theresa had moved her out of the apartment at 905
Tinton Avenue and Dayawathie had disappeared to parts unknown. The
case under which the writ of habeas corpus had been issued, No.
V-4534/95, was dismissed. I tried to reopen it, without success.
38. Almost immediately after the abortion of July 7, 1995, Dayawathie
became pregnant by a passing stranger. As a result, Geeta Rankoth, her
fourth child, was born June 9, 1996. Dayawathie believes that the
father was named Kamal and he was from Bangladesh but I have asked
around in the Bangladesh community and there is no such person from
Bangladesh in New York. The result is that instead of having a child
with me as the father, Dayawathie had a child by an unknown father.
Which is better? Geeta by the way is a wonderful child and I often
refer to her as my step-daughter.
39. The problem Theresa now has is that between 1991 and 1995
Dayawathie could not contact me because she did not know where I was
and I did not know where she was. However, now, Dayawathie knew where
I was and soon she called me and gave me her new address, which was on
Ft. Hamilton Parkway near Prospect Park. This was a facility operated
by Sanctuary for Families. In July 1996, I went there with my other
daughter Jessica, aged 7, and we met Dayawathie, Anusha and the
newborn baby Geeta near the subway station and spent the day in
Manhattan together. I then went with Jessica to play in the US Open
Chess Championship in Alexandria, Virginia. When we got back in New
York two weeks later, Dayawathie and the four children had been moved
out of the Ft. Hamilton Parkway facility. Apparently, Sister Theresa
Courtney had found out that we had met and had moved Dayawathie to
another facility.
40. In February, 1997, Dayawathie called me again. She had just been
given a new apartment on 1581 Park Avenue, New York NY This is in the
Johnson Housing Project at 113th Street and Lexington.. She asked me
to move in with her, which I did. We lived together there for several
months.
41. Unfortunately, soon thereafter some of the denizens she had left
behind in the Bronx found her. By then they had been evicted from
their own apartments in the same building, 905 Tinton Avenue, and now
they were staying with friends in the project across Lexington Avenue.
Soon, they moved into Dayawathie?fs apartment. Before long, we had
Jean, Julie, Jeans daughter, One-legged Brenda and new comers Brenda
Morales and Jimmy all living with me, Dayawathie and the four children
in the same two bedroom apartment. As Princess Diana later famously
commented, ?gIt was a bit crowded?g.
42. I tried to convince Dayawathie to lock these people out, but she
kept letting them in. They usually came home at about 2 AM. We later
found out that Brenda Morales and Jimmy were HIV Positive. This is the
reason they could not find any place else to live. Brenda Morales was
a professional thief. She would take my children, Anusha and George,
to stores and use them as decoys so that she could steal stuff. If she
was caught, the police would be reluctant to arrest her because of the
two children with her. Dayawathie knew about this but would do nothing
to stop it.
43. Julie, Jean and One-Legged Brenda were five-dollar prostitutes,
especially One-Legged Brenda. I suspect that she lost her leg to drug
addiction. They often smoked Crack. One-Legged Brenda gave birth to a
baby and social services immediately took the baby away from the
mother. A few days after One-Legged Brenda got back from delivering
the baby, I went to sleep in the apartment with nobody but me,
Dayawathie and the four children there. I was hoping to have a night
of peace. However, I woke up in the middle of the night to find that
One-Legged Brenda had crawled into bed with me. Some men would be
happy to find a woman in bed with them but I certainly was not happy,
especially since I knew that One- Legged Brenda was HIV Positive and a
crack addict. Dayawathie had opened the door and let Jean, Julie,
Jean?fs daughter and One-Legged into the apartment in the middle of
the night. Jean, Julie and Jean?fs daughter had taken over the beds in
which my children, Michael, George and Anusha were sleeping. They had
pushed Michael, George and Anusha onto the floor and were sleeping in
their beds while my children were now sleeping on the floor.
44. Finally, I had to act, so I secretly called 911. I reported that
drug addicts and prostitutes had pushed their way into our apartment,
which was true. The police arrived and I opened the door. They found
Jean, Julie, Jean?fs daughter and One-Legged Brenda all asleep. They
woke them up and searched the place but could not find any crack. All
the crack vials had been thrown down the garbage chute.
45. This was about 5:00 AM. While the police were doing this,
Dayawathie called Sister Theresa Courtney and woke her up. Dayawathie
did not tell Sister Threresa Courtney anything about Jean, Julie,
Jean?fs Daughter and One-Legged Brenda. Instead, she complained that I
was in the apartment (not mentioning that my then I had been living
there for four months). The end result was that the police took away
my keys to the apartment and told me to leave, which I did. Jean,
Julie, Jean's daughter and One-Legged Brenda were still allowed to
stay there. (I believe that Jimmy and Brenda Morales were not present
at the time of this incident.)
46. I was at that time working for a real estate holding company at 24
Sixth Avenue in Brooklyn. Twice, my other daughter, Jessica, and her
mother, Renuka, flew from Alameda California to visit us and each time
they stayed with Dayawathie and my other three children at 1581 Park
Avenue in New York. Dorchen Leidholdt found out about this and
approached Renuka and asked for her help in getting me arrested, but
Renuka refused to cooperate and instead went back to California.
47. During this time, Dayawathie was calling me 20 times a day at work
asking for stuff and this was disturbing my boss as work and made his
wife angry. I lost that job and I went to live with my friend from
Afghanistan, Sayed Durali Shah, who lives in Far Rockaway. Dayawathie
called me many times asking me to come back there, but I refused to
go. One night at about 7:00 PM Dayawathie called to say that Anusha
was very sick and needed to be taken to the hospital. However,
Dayawathie could not take her because she needed to take care of the
other three children. Therefore, Dayawathie wanted me to come to her
home and either take Anusha to the hospital or else stay with the kids
while Dayawathie took Anusha to the hospital.
48. I was very tired. I had been working as a taxi driver for Towne
Taxi in Lawrence Long Island. I wanted to go to sleep, but in view of
the emergency I got out of bed and made the two hour trip by subway
from Far Rockaway to Spanish Harlem where Dayawathie lived.
49. When I walked in the door to Dayawathie?fs apartment, I was
surprised to find Michael, George and Anusha running around playing
quite happily. Anusha did not look sick at all. Only one second later
two police officers came out the bedroom and arrested me. It had all
been a trap set by the police. The arresting officer was Carmen
Bonilla. She had sat by Dayawathie coaching her on exactly what to
say. This entire story about how Anusha was sick and needed to be
taken to the hospital was a pure fabrication. Dorchen Leidholdt was
involved in this, because as soon as she had arrested me Carmen
Bonilla called Dorchen Leidholdt on the phone to tell her the good
news. I was taken to jail.
50. They had made up a purely invented story that I had come to the
apartment with my 16-year-old girlfriend and had forced our way into
the apartment and had hit Dayawathie?fs head against the wall. Nothing
like that had ever occurred. Yes, there was such a girl, but she was
17, not 16, and we had been palling around for months but she was
never my girlfriend. Dayawathie had never met her. She had never been
to that apartment. Her name was Irina Novikova. She was from St.
Petersberg, Russia and I was giving her lessons in shogi, or Japanese
chess, of which I am a top player. She had converted to Hassidim and
lived in the Machon Chana in Crown Heights, Brooklyn, but every
Saturday she would sneak out to come to see me. Dayawathie had never
met her but had heard about her and was jealous and thus had invented
this entire story.
51. I called Irina Novikova from the jail and asked her to come to
court to testify in my defense. She said she would come, but did not
show up. Soon thereafter she went back to Russia and I never saw her
again until she returned to America four years later,
52. When the date came for the court hearing, Dorchen Leidholdt and
Dayawathie did not show up. In that event, they were supposed to
release me but instead they made a new bogus charge against me and put
me back in. Another six days passed. I was brought from the jail to
the courthouse. I sat all day in the waiting room behind the
courtroom. At 5:00 PM my court appointed lawyer came back to see me
and told me that Judge Ross had gone for the day. Therefore, there
would be no court hearing and I would be released as the case was
dismissed. By not allowing me to come before him in open court Judge
Ross had cheated me to my chance to complain that I had been held in
jail for 12 days for no reason at all. I attach a copy of a letter
from Dorchen Leidholdt saying that she was dropping the case because
she could not prove it ?gby a preponderance of the evidence?h. No
mention of ?gbeyond reasonable doubt?h. The letter was dated June 20
and had been delivered by hand. Nevertheless, Judge Ross had kept me
in jail until June 23 even though he knew that the case was being
dismissed.
53. I went to the office of the District Attorney several times
demanding that Dorchen Leidholdt be criminally prosecuted for bringing
this false case. However, the ADA, Eileen Chiu, said that she could do
nothing because again Dayawathie had disappeared. Dorchen Leidholdt
wrote a letter saying that she no longer represented Dayawathie and
did not know where she was. This was another lie. Dorchen had moved
Dayawathie to a facility Dorchen operated in Queens.
54. Before long, Dayawathie started calling me again. She was living
in a facility operated by Sister Theresa Courtney and Dorchen
Leidholdt at 166th Street and Hillside Avenue in Queens. She wanted me
to come there but I refused to go. She wanted me to buy presents for
the kids. Finally, I agreed to meet her at the big shopping mall on
33rd Street and Herald Square on Sixth Avenue in Manhattan. We met
many times there and I would treat the kids. There were no court
orders or custody orders because everything had been dissolved every
time she disappeared. Still, I was afraid to come to her residence.
55. In early 1998 she got a new apartment at 40-08 12th Street, Long
Island City, Queens, New York in the Queensbridge Housing Project. She
did not like the place, much preferring her old apartment in
Manhattan. However, she finally asked me to come live there. The deal
we made was that Sister Theresa Courtney and Dorchen Leidholdt only
came to see her on Saturday or Sunday and only came during the daytime
because they were afraid of the black people at night. Therefore, I
would never come at those times. I would maintain my own residence. If
Dorchen Leidholdt or Theresa Courtney ever came at an unusual time
when they were not expected, I would hide in a closet or in the
stairwell on a higher floor and leave the building as soon as they
entered the apartment. Dayawathie gave me keys to her apartment and to
the building and I could pretty much come and go as I pleased as long
as I followed those rules.
56. This has been the deal for the past seven years, from 1998 to
2005. As long as Dorchen Leidholdt and Theresa Courtney did not know
about it, I could even bring friends over. My other daughters, Shamema
and Jessica, have visited there. Jessica even lived there for a while.
I have ried and my wife Kayo and our daughter Sandra have been
frequent visitors in the home. Rusudan Goletiani, who is the US Womans
Chess Champion, has visited me there, as has my friend io
Sacripante for whom I worked when I was living in Japan in 1984. I
have also made friends with some of the neighbors. Thus, I have lots
of witnesses who could testify that I was freely coming and going in
the home for the past seven years. There has been no problem, no
arrests, no custody cases, for these seven years.
57. In 1999, my other daughter, Jessica, came from California to live
with me. However, she strongly preferred to stay with her
half-brothers and sisters, Michael, George and Anusha, so she lived in
Dayawathie?fs apartment at 40-08 12th Street, Long Island City. I
enrolled Jessica in school there, the same school that Michael and
George were attending. However, Dorchen Leidholdt and Sister Theresa
Courtney found out about this, went to the school and objected. As a
result, Jessica was not allowed to attend school there. I complained
to the Board of Education, to no avail. Finally I had to send Jessica
back to California.
58. There has been a big problem with Surinder Singh a/k/a Kala. He
was a homeless bum that Dayawathie had met while she was living in the
homeless shelter at 166th Street and Hillside Avenue. He followed her
to her new apartment at 40-08 12th Street. Dayawathie says that at
first he was nice. However, later, he was drunk all the time. He would
beat and abuse her. She would call 911. The police would come but he
would run away. Sometimes he would hide on the roof of the building
and come back down after the police left. Sometimes the police would
even catch him in the apartment but would not arrest him even though
he was obviously drunk and abusive. He was eventually arrested six
times in her apartment but then the judge would let him out after just
a few hours and he would come right back. Dayawathie got a dozen
orders of protection against him but he just ignored them.
59. Finally, the New York City Housing Department started an eviction
proceeding against Dayawathie for letting Surinder Singh into the
apartment where he would cause a constant commotion. Dayawathie got
Dorchen Leidholdt to defend her in this court case. Dorchen settled
the case with an order in which Dayawathie agreed not to allow
Surinder Singh OR Sam Sloan into her apartment, or otherwise she would
forfeit the apartment. Dorchen Leidholdt added my name to the case,
even though the New York City Housing Department had never heard of
me. They did not even know my name because the police had never been
called about me and there had never been any trouble about me.
60. This court order has made Dayawathie fearful of allowing me to
stay in the apartment. I have never spent the night there since. My
visits have been brief. Meanwhile, Kala has disappeared. I suspect
that he was finally deported back to India.
61. It is my absence that has allowed the two drug dealers from Tioga,
Pennsylvania to move in. They moved in full time in about February,
2005. Before that, they were just coming and going from Tioga to New
York. I know where they are from because one time Dayawathie went to
visit them in Tioga. She had me take care of the children while she
was gone and gave me the number there which she told me to call in
case of emergency, but she insisted that I never reveal that I had the
number.
61. From all of the above, it should be obvious that Jill Zuccardy,
Dorchen Leidholdt and Sanctuary for Families are disqualified from
appearing as counsel in this case. They have their own agenda which in
in conflict with the best interests of the mother and the children.
Rather than prove any case they might have against me, they repeatedly
uproot the children and disappear with them. They have had me arrested
three times but each time they have not come to court on the court
date and instead have disappeared with the children again. In 1997,
Dorchen Leidholdt wrote letters saying that she no longer represents
Dayawathie Rankoth and does not know where she is, but Dayawathie says
that there has never been even one day when Dorchen did not know where
she lives because she has been living in a facility provided by
Dorchen Leidholdt. Jill Zuccardy is a young lawyer who just graduated
from law school in 2005 and this must be one of his first cases. He
works for Sanctuary for Families and obviously does not know what he
is getting into.
62. Finally, Jill Zuccardy, Dorchen Leidholdt and Sanctuary for
Families tried to have me arrested again when this case was in court
on October 6, 2005. This is their tactic. They cannot prove their case
in court, so they want to win by having their opponent arrested and
then disappearing with the children so that the father cannot find
them again. This sort of behavior requires more than they be merely
disqualified from this case. They should be disbarred from the
practice of law.
63. Dorchen Leidholdt is a lesbian lunatic and a sick demented woman.
She founded an organization called �Victims of Pornography�. While
constantly railing in the press against pornography and organizing the
street demonstrations one sees from time to time, her writings are
actually pornographic. For example, her often cited statement that 25%
of all female children are sexually molested by their own fathers is
itself pornographic. For this reason, the statements by Dorchen
Leidholdt are often published in pornographic literature such as
Hustler Magazine. Hustler also publishes revealing pictures of Dorchen
Leidholdt taken when she was younger.
64. However, I do need to tell you about this, because you can read it
yourself. Attached hereto is a copy of an article Dorchen Leidholdt
wrote entitled, �When Women Defend Pornography�, which is found in the
book �The Sexual Liberals and the Attack on Feminism� by Dorchen
Leidholdt and Janice G. Raymond. This book is filled with essays by
militant lesbians, some of them quite famous. Anybody reading this
essay will immediately realize that the author is seriously ill and
emotionally disturbed.
65. Dorschen Leidholdt is the legal director for Sanctuary for
Families, She is the boss of Jill Zuccardy who is a new hire having
just graduated from Columbia University Law School in 2005. Dorchen
has founded numerous groups, one of which is the �Coalition Against
the International Trafficking of Women�. She uses my children and
their mother as the poster children for her organization. This is
obviously based on the fact that I brought the mother, Dayawathie
Rankoth, from Sri Lanka to America twice to give birth to my children.
66. Dorchen Leidholdt uses my children to collect charitable
contributions. She has established various 501(c)(3) corporations. In
short, she uses my children to make money. Wealthy people can get tax
deductions by donating to the various organizations which Dorchen
Leidholdt has founded. Dayawathie Rankoth thinks that Dortchen
Leidholdt is a nice lady her gives her money all the time but that is
because she fails to realize that what is really going on is Dorchen
Leidholdt is using her to make money. This is obviously a conflict of
interest.
67. Dorchen Leidholdt has had me arrested three times. In May and June
1995, I was held in jail mostly in the Alameda County Jail in Santa
Rita for 42 days on a charge of kidnapping. However, I was never
brought before a judge in court. California allows a person to be held
?gPending investigation?h. Meanwhile Dorchen Leidholdt had my two
sons, Michael and George, extradited to New York, which is why they
are here now.
68. She had me arrested twice again in 1997. I was living in Far
Rockaway Queens and driving a taxi for Towne Taxi in nearby Lawrence,
Long Island. Dorchen Leidholdt had Dayawathie call me and tell me that
Anusha was seriously ill and needed to be taken to the hospital and I
needed to come to her house right away. What I did not realize was
that Dorchen Leidholdt had taken out an order of protection against me
which I had never been served with so I did not know about. When I
appeared at the apartment to take Anusha to the hospital for this
serious illness she was supposedly suffering from, two police officers
were waiting to arrest me in a trap set by Dorchen Leidholdt.
69. Dorchen Liedholdt is doing the same thing here again. Here we have
an order of protection prohibiting me from seeing any of my children
including my eldest son Michael. However, Michael is not in the home.
He has been arrested and is in mental hospital. His case worker is
Nicole Valasko. She had called me and advises me that Michael should
not be returned to the home of Dayawathie Rankoth. Michael should live
with me, her father, she says. Two psychiatrists, Dr Arya and Dr.
Attila Polonyi, have made the same recommendation. I am sure that, if
asked, they would recommend that all three of my children be removed
from that home, especially since Dayawathie has had two drug dealers
living there. Yet, the court does not know about this, because of the
misconduct by Dorchen Leidholdt and her subordinate Jill Zuccardy. I
was not even allowed to sent Christmas presents to my children.
70. Jill Zuccardy, Dorchen Leidholdt and Sanctuary for Families tried
to have me arrested again when this case was in court on October 6,
2005. This is their tactic. They cannot prove their case in court, so
they want to win by having their opponent arrested and then
disappearing with the children so that the father cannot find them
again. This sort of behavior requires more than they be merely
disqualified from this case. They should be disbarred from the
practice of law.
WHEREFORE, for all of the reasons set forth above, Jill Zuccardy,
Dorchen Leidholdt and Sanctuary for Families should be disqualified
from appearing as counsel in this case.
___________________________
Samuel H.
Sloan
1664 Davidson
Avenue, Apt. 1B
Bronx NY 10453
[email protected]
917-507-7226
347-869-2465
Sworn to before me this 20th Day
of May, 2008
_______________________________
NOTARY PUBLIC
|
| | |
Date: 07 Aug 2008 13:29:07
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
80.I regret that I have not cited any cases an d this does not read
like a proper legal brief. I wan t to make one further point I passed
over previously. On November 13, 1990 Dayawathie filed a child custody
petition in the Family Court of Lynchburg, Virginia. Judge Dale Harris
of that court conducted several hearings in that case until June,
1991. During this time Dayawathie was living with me in my mother's
home in Lynchburg, Virginia. That is where she became pregnant with
Anusha, who was born non November 29, 1991. (By the way, I did not
have five girls locked up in different rooms of my mothers house and I
did not rape them every day.) Judge Dale Harris took jurisdiction over
this case and has never transferred jurisdiction. That was when
Dayawathie disappeared with the children. I brought Dayawathie to New
York in my car on what was supposed to be a one-day trip because she
was already under investigation by the Lynchburg Virginia Department
of Social Services. tha Tomlin was conducting that investigation.
She still works there and she still remembers the case which was
unusual, to say the least. It was for this reason that Appellant was
afraid to leave Dayawathie alone with the children and therefore
brought her to New York on that fateful day in June 1991, whereupon
Sanctuary for Families and Dorchen Leidholdt grabbed her away and
still has her to this day.
81.Therefore, I maintain that under the Uniform Child Custody Act, the
courts of New York lack the jurisdiction to deprive me of the custody
of my children.
82.Also, again, I assert that every time this cases is heard, Dorchen
Leidholdt and her gay minions assert that they are from �Sanctuary for
Families Center for Battered and Abused Women�. They are a private
organization founded and headed by Dorchen Leidholdt and are not in
any way a governmental organization. I believe that it is unfair and
prejudicial for them to be allowed to announce themselves in court
every time as from the �Sanctuary for Families Center for Battered and
Abused Women�. For this reason alone, this case should be reversed and
sent back down to the lower courts.
WHEREFORE, for all of the reasons set forth above, the petition by
Jill Zuccardy to dismiss this appeal on the grounds of res judicata
and collateral estoppal should be denied, and the decisions by the
court below should be vacated and reversed and remanded for new
hearings before a different judge and Sanctuary for Families and their
many attorneys should be disqualified from appearing in this case.
___________________________
Samuel H.
Sloan
1664 Davidson
Avenue, Apt. 1B
Bronx NY
10453-7877
[email protected]
917-507-7226
347-869-2465
Sworn to before me this 7th Day
of August, 2008
_______________________________
NOTARY PUBLIC
VERIFICATION
I, the undersigned, the petitioner named in the foregoing petition,
being duly sworn, says:
I have read the foregoing petition subscribed by me and know the
contents thereof and the same is true of my own knowledge, except as
to those matters herein stated to be alleged upon information and
belief and as to those matters I believe it to be true.
_________________________
Signature of
Petitioner
On the 7th Day of August, 2008 before me personally came Samuel Sloan
to me known to be the person described herein and who executed the
foregoing instrument. Such person duly swore to such instrument before
me and duly acknowledged that he executed the same.
_____________________________
NOTARY PUBLIC
|
| | |
Date: 07 Aug 2008 12:28:52
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
75.The egregious misconduct of Judge Modica resulted in a near
tragedy. Appellant had been bringing his three-year-old daughter
Sandra to court with him because he could not afford a baby sitter.
There is a mysterious order in the court file signed by Judge Modica
directing ACS to investigate that Appellant had been bringing his
three-year-old to court in a leash and harness. This order is
mysterious because there was no hearing on that date. Apparently
Sanctuary For Families again made an ex-party application without
telling me about it. When I came to court on January 6, 2006, Judge
Modica immediately had me locked up in the lunatic asylum. I am still
receiving bills from the ambulance company charging me $700 for taking
me to the hospital. I got out on January 11, 2006. Only two days later
I was taking my daughter Sandra to school. Up until then, I had always
put a harness and a leash on Sandra because she was, and still is,
extremely active and accident prone. Nobody knows my daughter better
than I do and this leash and harness was for Sandra's protection.
However, Judge Modica had ordered ACS to investigate this and for that
reason I could not put a leash and harness on Sandra any more.
76.On January 13, 2006, just two days after I had gotten out of the
loony bin, I was walking Sandra to school holding her hand as tightly
as I could. Across the street from her school, which was the Davidson
Avenue School, there is a children's playground with slides and
swings. Just as I was about ten yards from the school door, Sandra
suddenly broke loose from my grip and ran across the street to the
children's playground, right in front of a car that hit her and threw
her ten feet into the air.
77.Sandra was taken by ambulance to St. Barnabas Hospital, where the
emergency room crew did ten Cat scans. After about five hours, another
ambulance took her and me to Columbia Presbyterian Hospital, where she
remained for five days.
78.Fortunately, Sandra survived. It was a miracle. Has an adult been
hit directly by a car going that fact we would not have survived.
79.THIS ACCIDENT WAS ENTIRELY CAUSED BY JUDGE MODICA. IT WAS JUDGE
MODICA WHO FORCED ME TO TAKE THE LEASH AND HARNESS OFF OF MY
FOUR-YEAR-OLD DAUGHTER SANDRA. IT WAS BECAUSE OF JUDGE MODICA THAT MY
FOUR YEAR OLD DAUGHTER SANDRA RAN ACROSS THE STREET AND GOT HIT BY A
CAR. THEREFORE, I AM CALLING FOR THE ARRESTS, CRIMINAL PROSECUTION AND
LONG PRISON SENTENCE OF JUDGE SALDAVOR MODICA.
|
| | |
Date: 07 Aug 2008 12:04:28
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
50.This is a new issue that just came up when Referee Negron decided
that Appellant and Respondent are ried NOW which means that
Appellant is not ried to his current legal wife. Other than her
delusional testimony there is no evidence such as a riage
certificate showing that they are legally ried. True, Appellant has
sometimes referred to Petitioner as his common law wife in view of the
fact that they have three children together, but New York Law does not
recognize these common law arrangements. Just before the present case
was heard, there was an Order of Filiation case heard by Magistrate
Michael J. Fondacaro of the Queens Family Court on the same day,
October 6, 2005. See the Order on Page 16 of the Appendix to this
Appeal. This was necessary because Dayawathie has often been known to
state that Appellant in not the father of Anusha and Anusha has no
father at all!! A transcript of that proceeding has not been made
because it did not come up until now, but a transcript or tape will
show that Dayawathie testified that she has never been ried to
anybody and then, after receiving instructions from Alexander Karam,
changing her testimony. Please note that Magistrate Fondacaro found,
and his order states, that Appellant and Respondent had never been
ried and that Anusha was born "out of wedlock".At that hearing
Alexander Karam brought with him a big red brief-appendix type
document that appeared to be about 500 pages thick which turned out to
be a legal document presented to the Division of Immigration and
Naturalization, Department of Homeland Security for the purpose of
obtaining a green card for Dayawathie Rankoth. Appellant was not
allowed to see that document but it was handed up to the court who
proceeded to examine it. There is now a specific provision of law that
says that "Wives who are abused or battered by their U.S. citizen
husbands may self-petition themselves to gain lawful permanent status
(commonly called the green card). The Immigration and Nationality Act
(INA) has a provision that allows abused immigrant wives to file on
their own behalf without waiting for their U.S. citizen husband to
file for them." The application petition is often called the �battered
spouse petition� The form that must be filed is USCIS form I-360
http://www.philippinenews.com/article.php?id=2736
|
| | |
Date: 07 Aug 2008 11:48:38
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
62.Please recall that Judge Wong had threatened to have Appellant
arrested and locked up as soon as he walked in the door when this case
started. Obviously this was not an idle threat. However, regarding
Judge Modica's statement, �You have been convicted of a federal crime
by a federal judge. You have been convicted of a federal crime by a
federal judge�, this is demonstrable not true. Not only has Appellant
never been convicted, he has never been arrested, charged, accused or
even investigated for any federal crime. There is a website on the
Internet called the Federal Prisoner Inmate Locator:
http://www.bop.gov/iloc2/LocateInmate.jsp
63.Anybody who has ever been convicted of any federal crime in the
last 30 years or so can be found on that website. The name of
Appellant is not there. Thus, it is easily established that Appellant
has never been convicted of any federal crime by any federal judge.
64.More than that, the fact that Judge Modica made a statement that
can so easily be proven false demonstrates that it is actually Judge
Modica who is crazy. He should be removed from the bench.
65.Throughout these proceedings going back to 1991 when they started
17 years ago when Dayawathie was pregnant with Anusha, Dorchen
Leidholdt has made all kinds of allegations of sexual misconduct by
Appellant. As a result, there are several court orders in this case
directing various New York City agencies to investigate Appellant. The
result of all this is the appropriate District Attorney's office
submitted a report to the court stating that not only has Appellant
never been charged with a crime in New York, but he is not under
investigation for anything either. In short, Appellant has a clean
record. That report is in the file of this case. Unfortunately,
Appellant has not been allowed to copy that report and for that reason
it is not included in the Appendix.
66.On the other hand, when this case started, it was the Respondent
who was supposed to be investigated and a home study made. Appellant
is not aware of any such home study ever being made. There is nothing
about it in the case file to the extent that Appellant has been able
to see it. However, this case was previously pending in Manhattan
Family Court and Appellant submitted numerous documents from the case
files there showing very negative findings regarding Petitioner by
various social workers there. Although these documents were submitted
to the courts and the judges said that they would study the files of
the previous cases, there is no indication in their decisions that
they actually did.
67.Much is made of the case of Shamema Honzagool Sloan, the daughter
of Appellant. Appellant was charged with the �attempted abduction� of
Shamema in Virginia. However, documents submitted to the court
demonstrate that Appellant had legal custody on Shamema in New York
State, where she was born. Shemema was born in Columbia Presbyterian
Hospital in New York City on October 15, 1981. A few months later,
Judge Anthony Mercorella of the Bronx Supreme Court awarded legal
custody of Shamema to her mother, Honzagool, with visitation to the
father, Appellant. When Shamema was only nine months old her mother
abandoned her by returning to her native Pakistan and to this day has
never returned. Shamema was left with her father, Appellant. The
father subsequently obtained a modification of the existing order and
was given full legal custody of Shamema. Copies of the two orders of
the Bronx Supreme Court are included on Page 1266 and 1270 of the
Appendix. Those orders have never been modified. No order was ever
entered transferring this case to Virginia.
68.In September 1990, Charles and Shelby Roberts, fanatical followers
of Shelby Roberts, hired professional kidnappers to kidnap Shamema who
was then living with her father, the Appellant, in the United Arab
Emirates. Shamema was kidnapped and brought to Virginia. This is well
documented. Even the airline tickets that were used to bring the
kidnapped eight-year-old child to America are included in the
appendix. Charles Roberts even openly testified that he had paid
$4,000 as a down payment towards the kidnapping of Shamema. The
transcript is included.
69.The Amherst County Juvenile and Domestic Relations Court in Amherst
County Virginia was well aware that Appellant had legal custody in New
York having been presented with certified copies of the court orders,
and they knew that Shamema had been kidnapped from the United Arab
Emirates, but they proceeded to hear the petition by the Roberts for
legal custody of Shamema, in clear and obvious VIOLATION OF THE
UNIFORM CHILD CUSTODY ACT. All this is fully documented.
70.It is significant that Judge Michael Gamble had previously been the
attorney for Charles and Shelby Roberts during the period in question
up until the time he was appointed as a judge in ch 1991 (after
Shamema had been kidnapped and brought to Virginia). Also the two
attorneys on the side of the Roberts, Linda Groome and Lisa Schenkel,
were both instructors in Jerry Falwell's Liberty Christian Academy.
Their whole case was that neither the Appellant, Sloan, nor the
mother, Honzagool, should be allowed to have custody of Shamema,
because they were both Muslims. Therefore, Charles and Shelby Roberts,
non-relatives with no biological or legal connection to the child,
should be allowed to have custody, because they were God fearing
Christians and believers in Jerry Falwellism and �attended church
regularly�.
71.If one wants read something truly pathetic, read the transcript of
the so-called �trial� which is on pages 1287-1308 of the Appendix.
Both witnesses, both of whom were attorneys, testified that they were
not present in court on the dates of the incidents in question and in
fact they knew nothing about the case. Based solely on their testimony
and nothing else, Judge Gamble convicted Appellant. However, Judge
Gamble convicted Appellant not on what he had been charged with, nor
what the special prosecutor alleged, but for something that had not
even come up during the so-called trial. (A Special Prosecutor had
been appointed by Judge Gamble after the Amherst County Commonwealth
Attorney had refused to prosecute the case, saying that it had no
merit.) The reason Judge Gamble did all this is obvious, because, if
Appellant was not guilty of something, then Judge Gamble was guilty of
kidnapping because Judge Gamble's law firm had been involved in
helping the Roberts kidnap the child and bring her to Virginia in the
first place.
72.The case was partially appealed. The full case could not be
appealed because simultaneously with convicting Appellant Judge Gamble
had removed his counsel from the case. That is in the transcript.
Appellant did not realize this and for that reason filed a notice of
appeal one day late.
73.The part of the case that was appealed went to the Virginia Court
of Appeals. That case was affirmed in a split 2-1 decision. Appellant
then filed a Petition for Rehearing En Banc from his jail cell which
was GRANTED. (Appendix page 1388) The case then went for a full EN
Banc Hearing before the Virginia Court of Appeals. The result was a
split 6-3 decision. A reading of the courts decision, which is
included in the appendix but a better copy is available on Lexus
Nexus, shows that all nine judges agreed that Appellant was NOT GUILTY
of the charges. However, the majority of six ruled that the conviction
must be upheld because Appellant's court-appointed attorney had failed
to plead the right defense. The minority of three felt that Appellant
was totally not guilty at all. (Appellant had been given a very weak
court-appointed attorney after his paid attorney had been disqualified
and removed from the case by Judge Gamble.)
74. The dissenting opinion of Judge Koontz, which is found on page
1384 of the Appendix makes it clear and obvious that Appellant was not
remotely guilty and could never have been convicted by any proper
court.
|
| | |
Date: 07 Aug 2008 10:19:21
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
56.In short the entire report of Dr. k Rand was rubbish because
instead of doing what he is supposed to do as a trained psychologist,
which is to examine the patients before him, he instead was ordered by
the court to go out and read a bunch of stuff on the Internet and base
his findings on that. Because this vitally important part of this case
was total garbage, this entire proceeding needs to be thrown out by
this appellate court.
57.On November 15, 2006, Referee Negron ordered Polgar and �her
paramour Paul� who is Paul Truong in Case Number #: V-11575-06106A to
stop abusing their children by forcing them to take hot sauce as
punishment for playing bad moves at chess. This Vietnamese Hot Sauce
Case has been widely debated over the Internet. Referee Mildred
Negron, who was hearing both cases, could not possibly have known that
the perpetrators in the Hot Sauce Case were the same people who had
impersonated the Appellant here in this case over the Internet.
Appellant tried to testify about this matter before Referee Negron but
was not allowed to do so.
58.Another issue involved in this case concerns the behavior and
conduct of Judge Salvador Modica. On January 6, 2006, it is true that
Appellant came to court late. On the other hand on the previous court
date, Judge Modica had come to work one and a half hours late. Judge
Modica called the case without Appellant present and took testimony,
although there was a waiting room filled with other litigants waiting
for their cases to be heard. When the Appellant, Samuel Sloan, arrived
in court Judge Modica started screaming at him that he had appealed a
ruling by Judge Modica. Apparently Judge Miodica does not like to have
his rulings appealed. Appellant had in fact filed an appeal but his
appeal had been dismissed as an appeal from a non-appealable order.
Judge Modica then started screaming �You have been convicted of a
federal crime by a federal judge. You have been convicted of a federal
crime by a federal judge.� Judge Modica screamed these words over and
over again. Then Judge Modica ordered Appellant detained and taken to
Elmhurst Hospital to be held there for five days for psychiatric
examination and ordered the three-year-old daughter of Appellant who
the Appellant had brought to court detained by ACS. Appellant was then
locked up for five days.
59. Appellant requests and indeed demands that the judges of this
court play the tape recording on the brief hearing before Judge Modica
on January 6, 2006, which starts on page 1219 of the Appendix. This
court will clearly hear Judge Modica yelling and screaming while at
all times Appellant remained polite respectful. Nevertheless,
Appellant was locked up for five days. Also, his child, Sandra, was
detained by ACS. Fortunately, only a few hours later ACS turned Sandra
over to her mother, who is the legal wife of Appellant. The mother had
been working at her regular job in New Jersey on the day in question
and thus Appellant had brought their child to court.
60.After five days of being held in the lunatic asylum, Appellant was
returned to court and the insane asylum also sent a report by a
psychiatrist saying that Appellant is not crazy at all. That report by
Dr. Jennifer kus of Elmhurst Hospital stating that Appellant is NOT
CRAZY is on page 31 of the Appendix to this appeal.
61.This incident about Appellant being locked up in the lunatic asylum
for five days has been widely publicized on the Internet, although
Appellant has told nobody about it until now. Appellant wonders who
leaked information about this incident to the Internet press.
Appellant has certainly not told anybody about this, for obvious
reasons. Even though the end result was a letter from a psychiatrist
stating that Appellant is not crazy, this incident is not likely to be
viewed with favor. It also seems that what Judge Modica did was
ILLEGAL. A Judge simply cannot order an adult locked up for five days,
unless he had either been convicted of a crime or is dangerous to
himself or others. Thus, what Judge Modica did was illegal and not
only should this entire proceeding be thrown out, but Judge Modica
should be bounced off the court and disbarred from the practice of
law.
|
| | |
Date: 07 Aug 2008 09:41:07
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
Hey, you guys! Point out some typos. I cannot be expected to write
this brief all by myself.
Sam Sloan
|
| | |
Date: 07 Aug 2008 09:35:35
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
51.Appellant has never filed a petition sponsoring the Petitioner for
a green card based on a riage or fiancee visa or anything of that
nature. So, now we understand what this case is all about. In order to
get a green card, Petitioner must allege that she is (1) �a wife� and
(2) that she is battered and abused. Hence the case before this court.
She has a difficult case to prove because she came here on a tourist
visa but with a top-notch attorney like Alexander Karam she has
apparently succeeded.
52.Another issue before this court involves the reliance the
Petitioner and the Judge places on documents downloaded on the
Internet. The court directed an examination of the parties by a
psychologist named Dr. k Rand, Ph.D. - Forensic Psychological
Service, 5318 5TH Ave, Brooklyn, NY 11220-3111. Dr. Rand turned out to
be a former associate of Dr. Reuben Fine, a chess player whom
Appellant knew. During this examination, Dr. Rand stated that he was
not allowed to consider material downloaded from the Internet because
of a prior court decision.
53.Petitioner through her attorneys Dorchen Leidholdt, Alexander Karam
and Jill Zuccardy have sought to prove that Appellant is an unfit
father almost entirely based on material posted on the Internet. When
Dr. Rand refused to consider such material, they went to court any got
another judge, Judge Lenora Gerard, to sign an order REQUIRING Dr.
Rand to consider documents they had downloaded from the Internet. They
said that they had asked Judge Lenora Gerard to sign the order
because Judge Salvadore Modica was not in court that day. One wonders
what the rush was, since this case has been going on for three years.
54.The result was that Dr. Rand having been ordered by the court to
consider documents downloaded by Dorchen Leidholdt from the Internet
made a report which considered almost nothing else other than those
Internet documents. What Dr. Rand and the court probably did not know
is that Appellant is a victim of Impersonation on the Internet. There
are now cases pending in at least three different federal courts in
New York, Philadelphia and San Francisco involving the United States
Chess Federation and the impersonation of Sam Sloan on the Internet.
By fantastic coincidence, the perpetrators of these impersonations are
themselves the subject of a child abuse proceeding before Referee
Negron, the same judge in the same court. Their names are Susan Polgar
and Paul Truong. This case had been the subject of more than ten
articles in the New York Times and other newspapers around the country
and was even on Fox Radio News LAST WEEK:See
News Articles about USCF's suit against Polgar and Truong
http://kohm.org/news/?p=287
http://www.myfoxlubbock.com/myfox/pages/ContentDetail?contentId=7095694
Here are other newspaper articles in which these issues are being
discussed:
http://www.nytimes.com/2007/10/08/nyregion/08chess.html NY Times:
Chess Group Officials Accused of Using Internet to Hurt Rivals
http://gambit.blogs.nytimes.com/2007/10/10/interview-with-the-uscf-president-a-chess-sponsor-says-hes-had-enough/
NY Times: Interview With the U.S.C.F. President; a Chess Sponsor Says
He's Had Enough
http://gambit.blogs.nytimes.com/2007/10/19/founder-of-af4c-the-chess-federation-needs-a-new-structure/
NY Times: Founder of AF4C: The Chess Federation Needs a New Structure
http://gambit.blogs.nytimes.com/2007/10/23/polgar-responds-on-her-blog/
NY Times: Polgar Responds on her Blog
http://media.www.dailytoreador.com/media/storage/paper870/news/2007/10/24/News/Lawsuit.Creates.Problems.For.Local.Chess.Tournament-3051512.shtml
The Daily Toreador, Texas Tech University Student Newspaper: Lawsuit
Creates Problems for Local Chess Tournament
http://gambit.blogs.nytimes.com/2007/10/07/the-lawsuit-against-polgar-and-truong-a-closer-look
NY Times: The Lawsuit against Polgar and Truong, A Closer Look
http://gambit.blogs.nytimes.com/2007/10/08/the-lawsuit-against-polgar-and-truong-et-al-a-forum/
The Lawsuit Against Polgar and Truong, et al
55.A simple Google search for the terms �Sloan Polgar Chess� will
return dozens of newspaper articles and thousands of comments and
newsgroup postings about this case. Yet, Dr. k Rand knew about none
of this. He only knew about the Internet materials that Dorchen
Leidholdt had presented him with and Judge Lenora Gerard had ordered
him to consider. There is nothing to indicate in either the report by
Dr. k Rank or the decisions of the courts that he ever looked at
the actual website of Appellant, because had he looked at the website
he would have seen vast amounts of material about the game of chess
and he never mentioned anything like that. It is clear that he only
considered the materials that Dorchen Leidholdt presented him with
which she claimed were authored by Appellant. What those materials
exactly we do not know.
56.In short the entire report of Dr. k Rand was rubbish because
instead of doing what he is supposed to do as a trained psychologist,
which is to examine the patients before him, he instead was ordered by
the court to go out and read a bunch of stuff on the Internet and base
his findings on that. Because this vitally important part of this case
was total garbage, this entire proceeding needs to be thrown out by
this appellate court.
57.On November 15, 2006, Referee Negron ordered Polgar and �her
paramour Paul� who is Paul Truong in Case Number #: V-11575-06106A to
stop abusing their children by forcing them to take hot sauce as
punishment for playing bad moves at chess. This Vietnamese Hot Sauce
Case has been widely debated over the Internet. Referee Mildred
Negron, who was hearing both cases, could not possibly have known that
the perpetrators in the Hot Sauce Case were the same people who had
impersonated the Appellant here in this case over the Internet.
Appellant tried to testify before Referee Negron about this but was
not allowed to do so.
58.
|
| | |
Date: 07 Aug 2008 08:39:57
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
48.This indeed is the pattern of Dorchen Leidholdt. She does this
again and again in all kinds of cases, of which this is only one. She
has the children picked up and then disappears with them so that the
father can never find them. She calls her organization �Sanctuary for
Families� but in reality her mission is always to break up families.
Dayawathie, who has been involved with her since 1991, says that her
organization is only involved with women and never with men, except
for gay men. An official of social services has been quotes as saying,
�Sanctuary for Families will make a person disappear to such an extent
that you believe that the person no longer exists.�
49.It came out during the trial that Dorchen Leidholdt used this case
to get a green card for Dayawathie. Dayawathie was brought to America
this time on a tourist visa. This is not a riage case or anything
like that. There is a provision in immigration law that enables an
abused spouse to get a green card without meeting the normal
requirements. This is apparently what Dorchen did. The problem is that
Dayawathie was never ried. In fact, Dayawathie initially testified
that she had never been ried. I personally observed Alexander Karam
tell her to say that she had been ried and thus she changed her
testimony.
50.This is a new issue that just came up when Referee Negron decided
that Appellant and Respondent are ried NOW which means that
Appellant is not ried to his current legal wife. Other than her
delusional testimony there is no evidence such as a riage
certificate showing that they are legally ried. True, Appellant has
sometimes referred to Petitioner as his common law wife in view of the
fact that they have three children together, but New York Law does not
recognize these common law arrangements. Just before the present case
was heard, there was an Order of Filiation case heard by a Referee of
the Queens Family Court on the same day. See the Order on Page 16 of
the Appendix to this Appeal. This was necessary because Dayawathie has
often been known to state that Appellant in not the father of Anusha
and Anusha has no father at all!! A transcript of that proceeding has
not been made because it did not come up until now, but a transcript
or tape will show that Dayawathie testified that she has never been
ried to anybody and then, after receiving instructions from
Alexander Karam, changing her testimony. At that hearing Alexander
Karam brought with him a big red brief-appendix type document that
appeared to be about 500 pages thick which turned out to be a legal
document presented to the Division of Immigration and Naturalization,
Department of Homeland Security for the purpose of obtaining a green
card for Dayawathie Rankoth. Appellant was not allowed to see that
document but it was handed up to the court who proceeded to examine
it. There is now a specific provision of law that says that �Wives who
are abused or battered by their U.S. citizen husbands may
self-petition themselves to gain lawful permanent status (commonly
called the green card). The Immigration and Nationality Act (INA) has
a provision that allows abused immigrant wives to file on their own
behalf without waiting for their U.S. citizen husband to file for
them.� The application petition is often called the �battered spouse
petition� The form that must be filed is USCIS form I-360
http://www.philippinenews.com/article.php?id=2736
51.Appellant has never filed a petition sponsoring the Petitioner for
a green card based on a riage or fiancee visa or anything of that
nature. So, now we understand what this case is all about. In order to
get a green card, Petitioner must allege that she is (1) �a wife� and
(2) that she is battered and abused. Hence the case before this court.
She has a difficult case to prove because she came here on a tourist
visa but with a top-notch attorney like Alexander Karam she has
apparently succeeded.
|
| | |
Date: 07 Aug 2008 04:28:56
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: SECOND DEPARTMENT
---------------------------------------------------------------------X
No. 2008-02071
DAYAWATHIE RANKOTH,
Docket No. O-18182-05
Petitioner - Respondent
Queens County Family Court
- against -
AFFIDAVIT IN OPPOSITION
TO MOTION TO DISMISS
SAMUEL SLOAN, THIS
APPEAL
Respondent-Appellant.
----------------------------------------------------------------------X
Samuel H. Sloan, being duly sworn, deposes and says:
1.I make this affidavit in opposition to the motion by Jill Zuccardy
to dismiss my appeal.
2.I am totally shocked by this motion. This motion is entirely
frivolous and without basis. I am wondering what law school she
graduated from and how she passed the bar.
3.I cannot make out exactly what she is saying but she seems to be
saying at one point that my notice of appeal was filed late. In
reality I filed my notice of appeal as soon as I was able to obtain a
copy of the order appealed from, either the same day or the next day.
Miss Zuccardy seems to be saying that she does not know the date of
the order of the court. If she does not know the date, why is she
bothering us?
4.If she were any sort of lawyer she would know that the time to
appeal runs from the date of service of a copy of the order with
notice of entry. Since Miss Zuccardy never served the order, therefore
the time to appeal has not even started to run. It is amazing that she
does not even know this simple and obvious point.
5.Now, regarding her claim of res judicata, she made the same
allegation in another motion more than a month ago. Her motion at that
time was denied. It should be again denied now.
6.It is well established that in any sort of child custody litigation
there is no such thing as res judicata. Child custody matters are
always open and are never completely final. It is amazing that Jill
Zuccadry does not know this, since this is her area of practice.
7.On page 5, paragraph 7 of her �affirmation�, Jill Zuccardy cites
three cases on res judicata and collateral estoppal. None of those
cases are child custody cases. None of those cases have any similarity
to the case before this court.
8.The order appealed from is fundamentally different from the previous
order. As Miss Zuccardy admits, the judge of the Queens Family Court
made an oral decision from the bench, and when his written decision
came out it was something different. As I am pro se I did not notice
this, but Miss Zuccardy should have noticed it right away. Then the
case was referred by Judge Modica to Referee Negron. The case before
Referee Negron went on for another year. Then Referee Negron read in
open court what Judge Modica had said in his written decision. Referee
Negron immediately dismissed the proceeding before her saying that it
could not go forward in the face of Judge Modica's order. Since all
parties wanted the case before Referee Negron to continue to its
conclusion, everybody agreed to go back to Judge Modica and get a new
order. This was done.
9.At just about the exact time that this all was happening, this
Appellate Division affirmed the written order which was contrary to
the oral order of Judge Modica. The result is that everybody has, or
should have, egg on their faces, including all the lawyers involved,
the Family Court Judges and the appellate court judges.
10.Based on these facts it is obvious that there is no res judicata
here. This case was filed as a child custody case on July 30, 2005,
which was exactly three years ago. The intake judge ordered an
investigation into the Family of Dayawathie Rankoth and set the matter
for a hearing. She also appointed Vadim Cadet as guardian ad litem.
This last point is important because it means that the respondent,
Dayawathie Rankoth, knew about this case because her court-appointed
attorney told her.
11.The first hearing in this case was scheduled for October 6, 2005. I
was required to effectuate service of the summons at least 8 days
before that. Because I was concerned that what ultimately occurred
would occur, I decided not to hire a normal process server but rather
to go to the New York City Housing Police office and have them serve
the summons, as respondent was living in a New York City Housing
Project, namely the Queensbridge Project at 21st Street and 40th
Avenue. On three successive days, the New York City Housing Police
officers went to serve the summons while I waited in the Housing
Police station. On the first day, after I had waited many hours, the
police officer came back and said that he had knocked on the door
loudly many times and nobody was home. I knew that this was not true
because Dayawathie has five kids and is always home.
12.On the second day the police asked me to come with them, to make
sure that they were in the right place. Four police officers
accompanied me. Two went inside to serve the summons. The other two
waited outside of the building with me.
13.After about five minutes the two police officers who had gone
inside came back out and reported that a young girl had answered the
door (probably my daughter Anusha) and reported that her mother was in
the hospital.
14.Now I was in trouble because the summons was supposed to be served
8 days before the court date and this was the last day.
15.Nevertheless, I had no choice but to try again. I came again the
following day, which was now September 29, 2005, just seven days
before the court hearing date. This time I came to the housing police
station in the afternoon, earlier than the two previous days, because
coming at night when I assumed that she had to be home had not worked.
Also, that gave me a chance to try again later at night if once again
she was not at home when the police came to serve her with a summons.
16.As Officer Alan Fong later testified under subpoena during the
trial before Judge Modica, I waited several hours in the housing
police station on the afternoon of September 29, 2005. It was
necessary to wait because the shift was changing and several police
officers would be needed for this mission, because they were familiar
with Dayawathie Rankoth having been summoned to her apartment many
times because of incidents of domestic various involving several of
her paramours. (Several orders of protection against various paramours
of Dayawathie Rankoth are included in the Appendix on pages 47, 57 and
58.) Finally, a delegation of four police officers gathered together
and they all along with me proceeded to the Queensbridge Housing
Project to Serve the summons and complaint on Dayawathie Rankoth.
17.Upon arriving at building 40-08, two police officers including
Officer Alan Fong went inside the building to serve the summons. The
other two police officers waited outside with me just to make sure
nothing happened. As Officer Alan Fong later testified, he found the
Respondent at home this time and had a conversation with her. After
five or ten minutes he came back down and outside and essentially told
me to get the hell out of there, which I immediately did after he had
filled out and signed the officer's certificate of service of the
summons. That document, showing service by Officer Alan Fong on
Dayawathie Rankoth at 7:20 PM on September 29, 2005, is included on
Page 885 of the Appendix to this Appeal, Volume 2.
18.Officer Alan Fong later testified, under subpoena served by
Appellant, at the trial before Judge Modica. His testimony is in the
transcript which is included in the Appendix. Officer Fong testified
that he regularly patrols the Queensbridge Housing Project as part of
his regular duties as a housing police officer. He testified that he
had only seen Sam Sloan one time previously and that was about six
months before the incident in question and he had never seen Sam Sloan
since until he was subpoenaed to appear in court in this case.
19.Officer Fong testified that on September 29, 2005 he had observed
the Appellant waiting in the housing police station for several hours
prior to the incident in question. He had then accompanied Appellant
to the housing project. That Appellant had waited on the street
outside the building with two police officers. Meanwhile Officer Fong
had entered the building and served the summons. After Officer Fong
had served the summons, he came out of the building. He handed to
Appellant the completed form for service of the summons and Appellant
had immediately left the area and had never returned. Officer Fong
testified that the Appellant and the Respondent had never even seen
each other or had been anywhere near each other during the incident in
question, as Appellant had stayed out on the street and Respondent
had remained inside her apartment.
20. When the date arrived for the hearing scheduled for October 6,
2005, Respondent appeared with her attorney, Alexander Karam of
Sanctuary for Families. The case was set to be heard before Judge Wong
at 9:30 AM. Mr. Karam approached Judge Wong's Court Attorney, Tom
King, and told him that he had instructions to stop the hearing from
taking place and he wanted instructions on how to stop it. Mr. King
said that he would ask Judge Wong how to do this. He went into the
courtroom to ask.
21.Some time later Tom King came out of the courtroom and told
something to Alexander Karam. I stayed as near as they would allow me
to stay and I could hear some but not all of it. Soon Mr. King went
back in to ask another question on behalf of Alexander Karam. This
process continued throughout the day, with Mr. King passing messages
back and forth between Alexander Karam and Judge Wong. Meanwhile, I
was able to overhear Alexander Karam calling his boss, Dorchen
Leidholdt, on his cell phone informing her of the latest developments
and receiving instructions from her.
22.While this process was going on all the other cases scheduled for
9:30 AM were called and then the 10:00 and 10:30 cases. Although my
case was number 5 near the top of the calender, my case was not being
called. Finally, all the other scheduled cases except for my case had
been called and the court adjourned for lunch. During the lunch
period, I observed Alexander Karam receiving a package from Dorchen
Leidholdt being delivered by messenger.
23.I overheard the court attorney, Tom King, telling Alexander Karam
that if a petition were filed requesting an order of protection that
would take precedence over the custody petition and would stop the
custody hearing from taking place. Following this implied instruction,
Alexander Karam got in line at the desk where petitions are filed. I
saw him obtain a form to request an order of protection. I observed
him sitting on one of the benches with Dayawathie Rankoth, asking her
questions and filling in the form by hand. After the form was
completed, he handed it in.
24.B y now it was the afternoon court session. Judge Wong was hearing
�walk-in� cases, as all regularly scheduled cases had been heard.
Finally, Tom King came out of the courtroom and said that an order of
protection case had been filed and therefore under the rules of court
my child custody case could not be heard until the order of protection
case had been heard and decided. Therefore, Tom King asked me to agree
to an adjourned date.
25.It was obvious what was going on. Alexander Karam had told Tom King
that he wanted to �stop� the hearing that had been scheduled since
July 30, 2005 from taking place. Tim King told him that he could stop
the hearing by filing a petition for an order of protection. Alexander
Karam had done exactly that. However, I have consulted several
attorneys who practice regularly in Family Court and they say that
there is no such rule. One cannot stop a custody hearing simply by
filing a petition for an order of protection. Thus, Judge Wong's rule
was bogus. They also say that Judge Wong is not a Family Court Judge.
He is a Criminal Court Judge and was brought over to Family Court
because of a shortage of judges. They say that no regular judge of the
Family Court would make the same ruling that Judge Wong made.
26.When Tom King asked me to agree to a adjourned date, I vehemently
protested. I said that this hearing had already been delayed for more
than two months and I was demanding to be heard. Tom King went back
into the court room to relay this to Judge Wong.
27.Finally, at 3:30 PM my case was called. I had now been waiting six
hours since my case had been scheduled for 9:30 AM. Almost as soon as
I walked into the court room Judge Wong started screaming at me that
if I said a word he would have me arrested and locked up. The
transcript of what took place starts on Page 48 of the Appendix. His
first words were �I can sanction you which means putting you in jail�.
However, this transcript does not tell the real story because it does
not show that Judge Wong was yelling and screaming the entire time. I
request and indeed demand that the judges of this court obtain a tape
recording on the hearing that took place. You will be able to hear
Judge Wong yelling and screaming and me being polite and respectful.
28.Whereas I was not being allowed to say anything, Alexander Karam
was allowed to wax at great length. At this point I had not seen the
petition for an order of protection that Alexander Karam had handed
up. I was not able to obtain a copy until weeks later. It is on Page
20 of the Appendix. However, I heard in court Alexander Karam claiming
that I had �harassed� his client by coming to her house during the
period September 26-29, 2005. This is also the allegation on his
hand-written petition which can be seen on page 20 of the Appendix.
However, those dates, September 26-29, 2005, WERE THE EXACT DATES WHEN
I WAS COMING WITH THE NEW YORK CITY HOUSING POLICE TO SERVE HER WITH
THE SUMMONS.
29.In short, I had a complete and perfect defense to the allegations
because every time I had been there I had been accompanied by four
police officers. Obviously, had I done something wrong I would have
been arrested. Obviously, I was not arrested. Thus, I had done nothing
wrong. But, JUDGE WONG WOULD NOT ALLOW ME TO SPEAK. You can see from
the transcript that I repeatedly and politely asked to be heard. I was
not allowed to be heard and meanwhile Alexander Karam was being
allowed to talk on and on. Had I been allowed to respond that there
had been four police officers present and had Judge Wong done his
duty, this case for an order of protection would have been and should
have been dismissed then and there on the spot. Instead, it is still
going on, three years later. There have been a dozen different hearing
dates, more than one thousand pages of transcripts, hearings and
rehearings by judges of this and the lower courts, and meanwhile two
of my children by Dayawathie Rankoth have aged out of the system by
passing age 18.
30.Because of the egregious misconduct of Judge Doug Wong, I filed a
complaint against him for misconduct as a judge. I posted my complaint
on my website. My complaint against Judge Wong is on page 1031. The
letter rejecting my complaint is on page 56. However, only one week
later, Judge Wong was transferred out of the Queens Family Court, so
my letter may have had some effect. He has not been back.
31.I am informed by lawyers who practice regularly in the Queens
Family Court that what Judge Wong did was typical of him. He does this
all the time, especially yelling and screaming at parties who appear
before him. �He always does that�, I have been told.
32.Thus, this case should never have been before the courts in the
first place, and therefore it should not be before this court now. It
should have been dismissed in its inception.
33.Based entirely on a petition hand-written by Alexander Karam and
without hearing any testimony at all, Judge Wong issued an temporary
order of protection thus depriving Appellant of his children and the
children of their father for, so far, the past three years. Appellant
appealed, but this appeal was dismissed as a �non-appealable order�.
Incidentally, this sort of incident received some publicity on the
David Letterman Show when an obviously delusional woman who had never
met David Letterman obtained an order of protection prohibiting him
from thinking about her. See Restraining Orders Out of Control
http://www.thenewamerican.com/node/8647
34.That is only the beginning of a long story. In the protracted
proceedings over the next three years, there have been no witnesses
who have confirmed her story. I called as my witnesses her best friend
and neighbor, garet Shelton, our son, Michael Rankoth Sloan, and
officer Alan Fong. All of them testified that they had not seen me in
a long time. Michael Sloan, who still lives with his mother, the
appellant, testified that he had only seen me once in the past year,
when I cane to give him a birthday present. garet Shelton testified
that she had not seen me in a very long time. Officer Fong, who
patrols the housing project regularly, testified that he had only seen
me one other time in his life, and that was six months previously.
However, Dayawathie testified that I had come three or four times per
week for the past year and banged loudly on her door each time. This
even though I was living with my wife and child far away in Far
Rockaway Queens which is an hour and a half from Dayawathie's home in
Long Island City. Dayawathie even claimed that I had been arrested by
the police and taken out of her house, but there is no arrest record
or police report or any other documentation of this alleged incident.
35.The testimony of Dayawathie Rankoth can only be classified as
delusional. For example, she testified that I held her prisoner with
five other girls. Each girl was locked in a separate room of my house.
I raped each one of them every day. All of them were pregnant. When
asked why she did not report this to the police, she said that she was
afraid.
36.However, Appellant produced certified documents from the Lynchburg,
Virginia Family Court and the Lynchburg Department of Social Services
showing that during this time she had been living in Lynchburg in the
home of Dr. jorie Sloan, a distinguished and well respected child
psychiatrist. In fact, she had started a child custody case in
Lynchburg and she was under investigation by the Lynchburg Department
of Social Services, who still remembered the case. Indeed, she said
this herself, in her own delusional way: See
37.This case did not really start on July 30, 2005. It really started
in June 1991, the first day that Dayawathie arrived in New York City
after living for six months in Lynchburg. The judges of the Queens
Family Court have been informed of all proceedings in Lynchburg but
have ignored them. From reading the decision of Judge Modica one would
assume that she had been living in New York City the entire time. He
never explains how she got pregnant three times (actually four times)
with the children of the appellant. The third pregnancy occurred in
Lynchburg. The first two pregnancies were in Sri Lanka. Appellant
brought her to Oakland California to give birth to Michael so that
Michael would be an American citizen and then took her back to Sri
Lanka by way of Japan. Petitioner has traveled to 14 countries of the
world with Appellant to such diverse countries as Mexico and the
Soviet Union, yet the courts are asked to believe that she was locked
up in a house with four other girls and not allowed to escape.
38.The original proceeding in this case was started by Sebastian Ike a
case worker in the Bureau of Child Welfare, as ACS was then called,
who intended to start a proceeding to take the children away from her.
Among the reasons for this were unexplained scratches on Michael's
back. �Child Welfare Administration received a DSS-2221 Report that
Ms. Rankoth had beaten Michael excessively hard� (See Page 689 of the
Appendix).
39.Dayawathie told them that she wanted to return to Lynchburg where
she was living in the home of the paternal grandmother of the
children. The reports filed in the New York Manhattan Family Court in
this case show that Dayawathie was convinced to go to a shelter and
she finally agreed after first refusing. The BCW almost certainly did
not know that there were child abuse proceedings pending against her
already in Lynchburg. However, almost immediately thereafter,
Dayawathie Rankoth disappeared. Even the New York Society for the
Prevention of Cruelty to Children, who had been appointed as law
guardians in her case, were unable to find her. All reports after that
state, �No Record Found�.
40.Of course, now we know the reason. Sanctuary for Families had found
her and was hiding her. They were not merely hiding her from
Appellant. They were hiding her from the courts, the law guardians and
even from the New York Society for the Prevention of Cruelty to
Children.
41.All kinds of people were looking for her, including the Sri Lankan
Embassy, the New York Attorney General, the District Attorney and
various child welfare agencies. At the trial before Judge Modica she
testified that she had first met Dorchen Leidholdt when she was
pregnant wit Anusha and that at no time, from that date to this, has
there ever been a time when Dorchen Leidholdt did not know where she
was.
42.Yet, when this case was pending before Judge Richard Ross of the
Manhattan Family Court, Dorchen Leidholdt wrote a letter to the court
saying that she did not know where Dayawathis Rankoth was and she no
longer represented her. This was a lie. See 758 of the Appendix.
43.Next question is how did these children get to New York City in the
first place. Michael was born in Oakland California. After that she
returned to her native Sri Lanka, leaving Michael with Appellant.
Ultimately, Dorchen Leidholdt got the two eldest children picked up in
San Francisco California and brought to New York. She accomplished
this by filing a bogus habeas corpus petition which is found on page
775 of the Aoppendix.
44.Take a close look at this item. Notice that in the upper right
corner, there is an address in the Bronx. However, that address is
crossed out and over it is written 410 West 40th Street, New York NY.
That is actually the address of a church with a soup kitchen near Port
Authority Bus Terminal.
45.Dayawathie testified on open court that since coming to New York
City she had never lived in Manhattan. She had always lived in the
Bronx and that she was living on Tinton Avenue at the address that was
crossed out on the habeas corpus petition.
46.What actually happened was Dorchen knew a judge in Manhattan Family
Court who was friendly but she did not know any judges in the Bronx.
So in order to get the case heard in Manhattan she provided a FAKE
ADDRESS. Even that should not have worked. The judge should never have
signed the petition since the petition clearly states that the
children were in San Francisco, but he did anyway. This is a provable
and demonstrable example of CORRUPTION IN THE COURTS.
47.Based on this bogus proceeding, Dorchen got the Appellant arrested
and the children picked up and brought from San Francisco to New York.
When Appellant came to New York to get his children back, Dorchen had
moved them out of their apartment in the Bronx to a secret location.
Of course, the address of 410 West 40th Street was fake all along.
Thus, Appellant had lost his kids again and had no way to find them.
48.This indeed is the pattern of Dorchen Leidholdt. She does this
again and again in all kinds of cases, of which this is only one. She
has the children picked up and then disappears with them so that the
father can never find them. She calls her organization �Sanctuary for
Families� but in reality her mission is always to break up families.
Dayawathie, who has been involved with her since 1991, says that her
organization is only involved with women and never with men, except
for gay men.
49. It came out during the trial that Dorchen Leidholdt used this case
to get a green card for Dayawathie. Dayawathie was just brought to
America this time on a tourist visa. This is not a riage case or
anything like that. There is a provision in immigration law that
enables an abused spouse to get a green card without meeting the
normal requirements. This is apparently what Dorchen did. The problem
is that Dayawathie was never ried. In fact, Dayawathie initially
testified that she had never been ried. I personally observed
Alexander Karam tell her to say that she had been ried and thus she
changed her testimony.
|
| | |
Date: 07 Aug 2008 02:23:03
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: SECOND DEPARTMENT
---------------------------------------------------------------------X
No. 2008-02071
DAYAWATHIE RANKOTH,
Docket No. O-18182-05
Petitioner - Respondent
Queens County Family Court
- against -
AFFIDAVIT IN OPPOSITION
TO MOTION TO DISMISS
SAMUEL SLOAN, THIS
APPEAL
Respondent-Appellant.
----------------------------------------------------------------------X
Samuel H. Sloan, being duly sworn, deposes and says:
1.I make this affidavit in opposition to the motion by Jill Zuccardy
to dismiss my appeal.
2.I am totally shocked by this motion. This motion is entirely
frivolous and without basis. I am wondering what law school she
graduated from and how she passed the bar.
3.I cannot make out exactly what she is saying but she seems to be
saying at one point that my notice of appeal was filed late. In
reality I filed my notice of appeal as soon as I was able to obtain a
copy of the order appealed from, either the same day or the next day.
Miss Zuccardy seems to be saying that she does not know the date of
the order of the court. If she does not know the date, why is she
bothering us.
4.If she were any sort of lawyer she would know that the time to
appeal runs from the date of service of a copy of the order with
notice of entry. Since Miss Zuccardy never served the order, therefore
the time to appeal has not even started to run. It is amazing that she
does not even know this simple and obvious point point.
5.Now, regarding her claim of res judicata, she made the same
allegation in another motion more than a month ago. Her motion at that
time was denied. It should be again denied now.
6.It is well established that in any sort of child custody litigation
there is no such thing as res judicata. Child custody matters are
always open and are never completely final. It is amazing that Jill
Zuccadry does not know this, since this is her area of practice.
7.On page 5, paragraph 7 of her �affirmation�, Jill Zuccardy cites
three cases on res judicata and collateral estoppal. None of those
cases are child custody cases. None of those cases have any similarity
to the case before this court.
8.The order appealed from is fundamentally different from the previous
order. As Miss Zuccardy admits, the judge of the Queens Family Court
made an oral decision from the bench, and when his written decision
came out it was something different. As I am pro se I did not notice
this, but Miss Zuccardy should have noticed it right away. Then the
case was referred by Judge Modica to Referee Negron. The case before
Referee Negron went on for another year. Then Referee Negron read in
open court what Judge Modica had said in his written decision. Referee
Negron immediately dismissed the proceeding before her saying that it
could not go forward in the face of Judge Modica's order. Since all
parties wanted the case before Referee Negron to continue to its
conclusion, everybody agreed to go back to Judge Modica and get a new
order. This was done.
9.At just about the exact time that this all was happening, this
Appellate Division affirmed the written order which was contrary to
the oral order of Judge Modica. The result is that everybody has, or
should have, egg on their faces, including all the lawyers involved,
the Family Court Judges and the appellate court judges.
10.Based on these facts it is obvious that there is no res judicata
here. This case was filed as a child custody case on July 30, 2005,
which was exactly three years ago. The intake judge ordered an
investigation into the Family of Dayawathie Rankoth and set the matter
for a hearing. She also appointed Vadim Cadet as guardian ad litem.
This last point is important because it means that the respondent,
Dayawathie Rankoth, knew about this case because her court-appointed
attorney told her.
11.The first hearing in this case was scheduled for October 5, 2005. I
was required to effectuate service of the summons at least 8 days
before that. Because I was concerned that what ultimately occurred
would occur, I decided not to hire a normal process server but rather
to go to the New York City Housing Police office and have them serve
the summons, as respondent was living in a New York City Housing
Project, namely the Queensbridge Project at 21st Street and 40th
Avenue. On three successive days, the New York City Housing Police
officers went to serve the summons while I waited in the Housing
Police station. On the first day, after I had waited many hours, the
police officer came back and said that he had knocked on the door
loudly many times and nobody was home. I knew that this was not true
because Dayawathie has five kids and is always home.
12.On the second day the police asked me to come with them, to make
sure that they were in the right place. Four police officers
accompanied me. Two went inside to serve the summons. The other two
waited outside of the building with me.
13.After about five minutes the two police officers who had gone
inside came back out and reported that a young girl had answered the
door (probably my daughter Anusha) and reported that her mother was in
the hospital.
14.Now I was in trouble because the summons was supposed to be served
8 days before the court date and this was the last day.
15.Nevertheless, I had no choice but to try again. I came again the
following day, which was now September 29, 2005, just seven days
before the court hearing date. This time I came to the housing police
station in the afternoon, earlier than the two previous days, because
coming at night when I assumed that she had to be home had not worked.
Also, that gave me a chance to try again later at night if once again
she was not at home when the police came to serve her with a summons.
16.As Officer Alan Fong later testified under subpoena during the
trial before Judge Modica, I waited several hours in the housing
police station on the afternoon of September 29, 2005. It was
necessary to wait because the shift was changing and several police
officers would be needed for this mission, because they were familiar
with Dayawathie Rankoth having been summoned to her apartment many
times because of incidents of domestic various involving several of
her paramours. (Several orders of protection against various paramours
of Dayawathie Rankoth are included in the Appendix on pages 47, 57 and
58.) Finally, a delegation of four police officers gathered together
and they all along with me proceeded to the Queensbridge Housing
Project to Serve the summons and complaint on Dayawathie Rankoth.
17.Upon arriving at building 40-08, two police officers including
Officer Alan Fong went inside the building to serve the summons. The
other two police officers waited outside with me just to make sure
nothing happened. As Officer Alan Fong later testified, he found the
Respondent at home this time and had a conversation with her. After
five or ten minutes he came back down and outside and essentially told
me to get the hell out of there, which I immediately did after he had
filled out and signed the officer's certificate of service of the
summons. That document, showing service by Officer Alan Fong on
Dayawathie Rankoth at 7:20 PM on September 29, 2005, is included on
Page 885 of the Appendix to this Appeal, Volume 2.
18.Officer Alan Fong later testified, under subpoena served by
Appellant, at the trial before Judge Modica. His testimony is in the
transcript which is included in the Appendix. Officer Fong testified
that he regularly patrols the Queensbridge Housing Project as part of
his regular duties as a housing police officer. He testified that he
had only seen Sam Sloan one time previously and that was about six
months before the incident in question and he had never seen Sam Sloan
since until he was subpoenaed to appear in court in this case.
19.Officer Fong testified that on September 29, 2005 he had observed
the Appellant waiting in the housing police station for several hours
prior to the incident in question. He had then accompanied Appellant
to the housing project. That Appellant had waited on the street
outside the building with two police officers. Meanwhile Officer Fong
had entered the building and served the summons. After Officer Fong
had served the summons., he came out of the building. He handed the
completed form for service of the summons and Appellant had
immediately left the area and had never returned. Officer Fong
testified that the Appellant and the Respondent had never even seen
each other or had been anywhere near each other during the incident in
question, as Appellant had stayed out on the street and Respondent
had remained inside her apartment.
20. When the date arrived for the hearing scheduled for October 6,
2005, Respondent appeared with her attorney, Alexander Karam of
Sanctuary for Families. The case was set to be heard before Judge Wong
at 9:30 AM. Mr. Karam approached Judge Wong's Court Attorney, Tom
King, and told him that he had instructions to stop the hearing from
taking place and he wanted instructions on how to stop it. Mr. King
said that he would ask Judge Wong how to do this. He went into the
courtroom to ask.
21.Some time later Tom King came out of the courtroom and told
something to Alexander Karam. I stayed as near as they would allow me
to stay and I could hear some but not all of it. Soon Mr. King went
back in to ask another question on behalf of Alexander Karam. This
process continued throughout the day, with Mr. King passing messages
back and forth between Alexander Karam and Judge Wong. Meanwhile, I
was able to overhear Alexander Karam calling his boss, Dorchen
Leidholdt, on his cell phone informing her of the latest developments
and receiving instructions from her.
22.While this process was going on all the other cases scheduled for
9:30 AM were called and then the 10:00 and 10:30 cases. Although my
case was number 5 near the top of the calender, my case was not being
called. Finally, all the other scheduled cases except for my case had
been called and the court adjourned for lunch. During the lunch
period, I observed Alexander Karam receiving a package from Dorchen
Leidholdt being delivered by messenger.
23.I overheard the court attorney, Tom King, telling Alexander Karam
that if a petition were filed requesting an order of protection that
would take precedence over the custody petition and would stop the
custody hearing from taking place. Following this implied instruction,
Alexander Karam got in line at the desk where petitions are filed. I
saw him obtain a form to request an order of protection. I observed
him sitting on one of the benches with Dayawathie Rankoth, asking her
questions and filling in the form by hand. After the form was
completed, he handed it in.
24.B y now it was the afternoon court session. Judge Wong was hearing
�walk-in� cases, as all regularly scheduled cases had been heard.
Finally, Tom King came out of the courtroom and said that an order of
protection case had been filed and therefore under the rules of court
my child custody case could not be heard until the order of protection
case had been heard and decided. Therefore, Tom King asked me to agree
to an adjourned date.
25.It was obvious what was going on. Alexander Karam had told Tom King
that he wanted to �stop� the hearing that had been scheduled since
July 30, 2005 from taking place. Tim King told him that he could stop
the hearing by filing a petition for an order of protection. Alexander
Karam had done exactly that. However, I have consulted several
attorneys who practice regularly in Family Court and they say that
there is no such rule. One cannot stop a custody hearing simply by
filing a petition for an order of protection. Thus, Judge Wong's rule
was bogus. They also say that Judge Wong is not a Family Court Judge.
He is a Criminal Court Judge and was brought over to Family Court
because of a shortage of judges. They say that no regular judge of the
Family Court would make the same ruling that Judge Wong made.
26.When Tom King asked me to agree to a adjourned date, I vehemently
protested. I said that this hearing had already been delayed for more
than two months and I was demanding to be heard. Tom King went back
into the court room to relay this to Judge Wong.
27.Finally, at 3:30 PM my case was called. I had now been waiting six
hours since my case had been scheduled for 9:30 AM. Almost as soon as
I walked into the court room Judge Wong started screaming at me that
if I said a word he would have me arrested and locked up. The
transcript of what took place starts on Page 48 of the Appendix. His
first words were �I can sanction you which means putting you in jail�.
However, this transcript does not tell the real story because it does
not show that Judge Wong was yelling and screaming the entire time. I
request and indeed demand that the judges of this court obtain a tape
recording on the hearing that took place. You will be able to hear
Judge Wong yelling and screaming and me being polite and respectful.
28.Whereas I was not being allowed to say anything, Alexander Karam
was allowed to wax at great length. At this point I had not seen the
petition for an order of protection that Alexander Karam had handed
up. I wax not able to obtain a copy until weeks later. It is on Page
20 of the Appendix. However, I heard in court Alexander Karam claiming
that I had �harassed� his client by coming to her house during the
period September 26-29, 2005. This is also the allegation on his
hand-written petition which can be seen on page 20 of the petition.
However, those dates, September 26-29, 2005, WERE THE EXACT DATES WHEN
I WAS COMING WITH THE NEW YORK CITY HOUSING POLICE TO SERVE HER WITH
THE SUMMONS.
29.In short, I had a complete and perfect defense to the allegations
because every time I had been there I had been accompanied by four
police officers. Obviously, had I done something wrong I would have
been arrested. Obviously, I was not arrested. Thus, I had done nothing
wrong. But, JUDGE WONG WOULD NOT ALLOW ME TO SPEAK. You can see from
the transcript that I repeatedly and politely asked to be heard. I was
not allowed to be heard and meanwhile Alexander Karam was being
allowed to talk on and on. Had I been allowed to respond that there
had been four police officers present and had Judge Wong done his
duty, this case for an order of protection would have been and should
have been dismissed then and there on the spot. Instead, it is still
going on, three years later. There have been a dozen different hearing
dates, more than one thousand pages of transcripts, hearings and
rehearings by judges of this and the lower courts, and meanwhile two
of my children by Dayawathie Rankoth have aged out of the system by
passing age 18.
30.Because of the egregious misconduct of Judge Doug Wong, I filed a
complaint against him for misconduct as a judge. I posted my complaint
on my website. My complaint against Judge Wong is on page 1031. The
letter rejecting my complaint is on page 56. However, only one week
later, Judge Wong was transferred out of the Queens Family Court, so
my letter may have had some effect. He has not been back.
31.I am informed by lawyers who practice regularly in the Queens
Family Court that what Judge Wong did was typical of him. He does this
all the time, especially yelling and screaming at parties who appear
before him. �He always does that�, I have been told.
32.Thus, this case should never have been before the courts in the
first place, and therefore it should not be before this court now. It
should have been dismissed in its inception.
|
| | |
Date: 07 Aug 2008 00:07:36
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: SECOND DEPARTMENT
---------------------------------------------------------------------X
No. 2008-02071
DAYAWATHIE RANKOTH,
Docket No. O-18182-05
Petitioner - Respondent
Queens County Family Court
- against -
AFFIDAVIT IN OPPOSITION
TO MOTION TO DISMISS
SAMUEL SLOAN, THIS
APPEAL
Respondent-Appellant.
----------------------------------------------------------------------X
Samuel H. Sloan, being duly sworn, deposes and says:
1.I make this affidavit in opposition to the motion by Jill Zuccardy
to dismiss my appeal.
2.I am totally shocked by this motion. This motion is entirely
frivolous and without basis. I am wondering what law school she
graduated from and how she passed the bar.
3.I cannot make out exactly what she is saying but she seems to be
saying at one point that my notice of appeal was filed late. In
reality I filed my notice of appeal as soon as I was able to obtain a
copy of the order appealed from, either the same day or the next day.
Miss Zuccardy seems to be saying that she does not know the date of
the order of the court. If she does not know the date, why is she
bothering us.
4.If she were any sort of lawyer she would know that the time to
appeal runs from the date of service of a copy of the order with
notice of entry. Since Miss Zuccardy never served the order, therefore
the time to appeal has not even started to run. It is amazing that she
does not even know this simple and obvious point point.
5.Now, regarding her claim of res judicata, she made the same
allegation in another motion more than a month ago. Her motion at that
time was denied. It should be again denied now.
6.It is well established that in any sort of child custody litigation
there is no such thing as res judicata. Child custody matters are
always open and are never completely final. It is amazing that Jill
Zuccadry does not know this, since this is her area of practice.
7.On page 5, paragraph 7 of her �affirmation�, Jill Zuccardy cites
three cases on res judicata and collateral estoppal. None of those
cases are child custody cases. None of those cases have any similarity
to the case before this court.
8.The order appealed from is fundamentally different from the previous
order. As Miss Zuccardy admits, the judge of the Queens Family Court
made an oral decision from the bench, and when his written decision
came out it was something different. As I am pro se I did not notice
this, but Miss Zuccardy should have noticed it right away. Then the
case was referred by Judge Modica to Referee Negron. The case before
Referee Negron went on for another year. Then Referee Negron read in
open court what Judge Modica had said in his written decision. Referee
Negron immediately dismissed the proceeding before her saying that it
could not go forward in the face of Judge Modica's order. Since all
parties wanted the case before Referee to continue to its conclusion,
everybody agreed to go back to Judge Modica and get a new order. This
was done.
9.At just about the exact time that this all was happened, this
Appellate Division affirmed the written order which was contrary to
the oral order of Judge Modica. The result is that everybody has, or
should have, egg on their faces, including all the lawyers involved,
the Family Court Judges and the appellate court judges.
10.Based on these facts it is obvious that there is no res judicata
here. This case was filed as a child custody case on July 30, 2005,
which was exactly three years ago. The intake judge ordered an
investigation into the Family of Dayawathie Rankoth and set the matter
for a hearing. She also appointed Vadim Cadet as guardian ad litem.
This last point is important because it means that the respondent,
Dayawathie Rankoth, knew about this case because her court-appointed
attorney told her.
11.The first hearing in this case was scheduled for October 5, 2005. I
was required to effectuate service of the summons at least 8 days
before that. Because I was concerned that what ultimately occurred
would occur, I decided not to hire a normal process server but rather
to go to the New York City Housing Police office and have them serve
the summons, as respondent was living in a New York City Housing
Project, namely the Queensbridge Project at 21st Avenue and 40th
Street. On three successive days, the New York City Housing Police
officers went to serve the summons while I waited in the Housing
Police station. On the first day, after I had waited many hours, the
police officer came back and said that he had knocked on the door
loudly many times and nobody was home. I knew that this was not true
because Dayawathie has five kids and is always home.
12.On the second day the police asked me to come with them, to make
sure that they were in the right place. Four police officers
accompanied me. Two went inside to serve the summons. The other two
waited outside of the building with me.
13.After about five minutes the two police officers who had gone
inside came back out and reported that a young girl had answered the
door (probably my daughter Anusha) and reported that her mother was in
the hospital.
14.Now I was in trouble because the summons was supposed to be served
8 days before the court date and this was the last day.
15.Nevertheless, I had no choice but to try again. I came again the
following day, which was now September 29, 2005, just seven days
before the court hearing date. This time I came to the housing police
station in the afternoon, earlier than the two previous days, because
coming at night when I assumed that she had to be home had not worked.
Also, that gave me a chance to try again later at night if once again
she was not at home when the police came to serve her with a summons.
16.As Officer Alan Fong later testified under subpoena during the
trial before Judge Modica, I waited several hours in the housing
police station on the afternoon of September 29, 2005. It was
necessary to wait because the shift was changing and several police
officers would be needed for this mission, because they were familiar
with Dayawathie Rankoth having been summoned to her apartment many
times because of incidents of domestic various involving several of
her paramours. Finally a delegation of four police officers gathered
together and they all with me proceeded to the Queensbridge Housing
Project to Serve the summons and complaint on Dayawathie Rankoth.
17.Upon arriving at building 40-08, two police officers including
Officer Alan Fong went inside the building to serve the summons. The
other two police officers waited outside with me just to make sure
nothing happened. As Officer Alan Fong later testified, he found the
Respondent at home this time and had a conversation with her. After
five or ten minutes he came back down and outside and essentially told
me to get the hell out of there, which I immediately did after he had
filled out and signed the officers certificate of service. That
document, showing service by Officer Alan Fong on Dayawathie Rankoth
at 7:20 PM on September 29, 2005 is included on Page 885 of the
Appendix to this Appeal, Volume 2.
18.Officer Alan Fong later testified under subpoena served by
Appellant at the trial before Judge Modica. His testimony is in the
transcript which is included in the Appendix. Officer Fong testified
that he regularly patrols the Queensbridge Housing Project as part of
his regular duties as a housing police officer. He testified that he
had only seen Sam Sloan one time previously and that was about six
months before the incident in question and he had never seen Sam Sloan
since until he was subpoenaed to appear in court in this case.
19.Officer Fong testified that he had observed the Appellant waiting
in the housing police station for several prior to the incident in
question. He had accompanied Appellant to the housing project. That
Appellant had waited on the street outside the building with two
police officers. Meanwhile Officer Fong had entered the building and
served the summons. After Officer Fong came out of the building he had
handed the completed form for service of the summons and Appellant had
immediately left the area and had never returned. Officer Fong
testified that the Appellant and the Respondent had never even seen
each other or been anywhere near each other during the incident in
question, as he stayed out on the street and she remained inside her
apartment.
20. When the date arrived for the hearing scheduled for October 6,
2005, Respondent appeared with her attorney, Alexander Karam of
Sanctuary for Families. The case was set to be heard before Judge Wong
at 9:30 AM. Mr. Karam approached Judge Wong's Court Attorney and told
him that he had instructions to stop the hearing from taking place and
he wanted instructions on how to stop it. Mr. King said that he would
ask Judge Wong how to do this and went into the courtroom to ask.
21.Some time later Tom King came out of the courtroom and told
something to Alexander Karam. I stayed as near as they would allow me
to and I could hear some but not all of it. Soon Mr. King went back in
to ask another question on behalf of Alexander Karam. This process
continued throughout the day, with Mr. King passing messages back and
forth between Alexander Karam and Judge Wong. Meanwhile, I was able to
overhear Alexander Karam calling his boss, Dorchen Leidholdt on his
cell phone informing her of the latest developments and receiving
instructions from her.
22.While this process was going on all the cases scheduled for 9:30 Am
were called and then the 10:00 and 10:30 cases. Finally all the other
scheduled cases except for my case and the court adjourned for lunch.
During the lunch period I observed Alexander Karam receiving a package
from Dorchen Leidholdt being delivered by messenger.
23.
|
| | |
Date: 06 Aug 2008 23:01:27
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
SUPREME COURT OF THE STATE OF NEW YORK
APPELLATE DIVISION: SECOND DEPARTMENT
---------------------------------------------------------------------X
No. 2008-02071
DAYAWATHIE RANKOTH,
Docket
No. O-18182-05
Petitioner - Respondent
Queens County
Family Court
- against -
SAMUEL SLOAN,
Respondent-Appellant.
----------------------------------------------------------------------X
APPELLANT'S BRIEF AND APPENDIX
VOLUME 2
Index of Rankoth vs. Sloan
Appendix Volume One
Notice of Appeal
1
Order Appealed From
2
Summons in Sloan vs. Rankoth
6
Paternity Petition
9
Sloan Custody Petition
12
Order for ACS to Make Home Study
14
Notification of Order of Filiation
16
Birth Certificate of Anusha Sloan
19
Petition by Dayawathie Rankoth
20
Order dated October 5, 2005
22
Order for Investigation Amended
25
Order dated November 28, 2005
26
Order Directing Mental Examination (Inpatient)
29
Psychiatric Examination of Samuel Sloan
31
Order dated ch 10, 2006
32
Order dated April 26, 2006
35
Order dated June 26, 2006
38
Order dated July 7, 2006
41
Order dated August 3, 2006
44
Orders Protesting �Samuel Sloan and Family� from Surinder Singh
47
Transcript dated October 6,. 2005
48
Letter from Cheryl Joseph-Cherry in response to complaint
56
Orders Protesting �Samuel Sloan and Family� from Surinder Singh
57
Transcript dated January 20, 2006
59
Transcript dated February 6, 2006
167
Transcript dated ch 10, 2006
244
Transcript dated June 26, 2006
331
Transcript dated August 3, 2006
474
Transcript of decision of August 3, 2006
566
Notice to Produce
573
Letter to Principal of Long Island City High School about George
574
Birth Certificate of George Rankoth Sloan
575
Documents from 1991 ACS Investigation of Dayawathie Rankoth
576
Letter from Queens Child Guidance Center
581
Report of Investigation by New York Society for the Prevention of
Cruelty to
Children
582
Affirmation by Rosmonde-Pierre Louis, attorney for Sanctuary for
Families 589
Domestic Incidence Report
593
Motion to Disqualify Alexander Karam
596
Report from Elmhurst Hospital Center
597
Order Authorizing Forensic Services
598
Letter from Vladimir Cadet
600
Forensic Report by Dr. k Rand
601
Decision and Order by Judge Modica
649
Motion for an Order to Show Cause of June, 1997
658
Letter from Sanctuary for Families dated June 20, 1997
669
Affidavit of ADA Jacoby
672
Violation of Order of Protection
673
Letter to Natalie Jacobi dated June 26, 1997
676
Letter from Secretary for Judge Ross to Respondent
678
Who is Dorchen Leidholdt?
679
Summons in Family Court dated May 6, 1997
680
Summons (never served)
684
Motion for an Order to Show Cause
686
Letter from Sebastian Ike
695
Interview with Petitioner
696
�Child Welfare Administration received a DSS-2221 Report that
Ms. Rankoth had beaten Michael excessively hard�
698
�Mrs. Rankoth stated that she and the children would return to
Virginia by bus.
They would live in the home of Mr. Sloan's mother.�
699
Appendix Volume Two
Report of Investigation by New York Society for the Prevention of
Cruelty to
Children
702-708
Subpoena to garet Shelton
709
Subpoena to Michael Sloan
710
Motion to Disqualify Alexander Karam
713
Dupe of page 669
725
All Purpose Short Order by Judge Ross
726
Notice of Renewed Motion to Disqualify Alexander Karam
727
Dorchen Leidholdt Wikipedia Biography
731
�The Sexual Liberals and the Attack on Feminism� by Dorchen Leidholdt
733
�When Women Defend Pornography� by Dorchen Leidholdt
734
Hustler Magazine Article �Asshole of the Month Dorchen Leidholdt�
742
Speech by Dorchen Leidholdt Co-Executive Director on Trafficking of
Women 743
Affidavit in Opposition to Motion to Vacate
748
Dupe of page 669 but with notes at the top
754
Last page of petition dated April 21, 1997
755
Order of y Bednar
756
Dupe of page 726
757
Letter from Dorchen Leidholdt dated June 22, 1997
758
Writ of Habeas Corpus
759
Dupe of page 756
764
Dupe of page 589
765
Dupe �cannot be located�
769
Dupe of page 581
772
Letter from Molly's Professional Typing
774
Dupe of Kaplan Habeas Corpus
775
Appeal to Appellate Division
777
Petition by Dayawathie (only two pages)
778
Dupe of Summons on page
780
Another Dupe of Rosemonde Aff
781
Another habeas
785
Appeal from Ross
786
Wong handwritten notes
787
Affidavit in Opposition dupe
788
Summons by Officer Fong
793
Affirmation in Opposition by Karam plus exhibits
794
Answer to petition and counter-claim
806
Amended petition by Rankoth
833
Westlaw Report of Decision
839
Affidavit in Opposition dupe
840
Letter to School Principal about Anusha
845
Order of Filiation Dupe
846
Amended petition dupe
847
Handwritten letter to Judge Kaplan from jail
850
Temporary Order by Judge Ross
852
Short Order dupe
853
Family Court summons 1997
854
Family Court petition 1997
855
Answer to Family Offense Petition
859
Letter from Sanctuary for Families to Public School 1996
870
Letter authorizing release of information
871
Letter notifying that the case is considered unfounded
872
Letter regarding Dayawathie failed to keep appointment
873
Motion to Vacate ex-party temporary order of protection
874
Violation of Order of Protection
877
Bail order by Judge Ross
878
Judges Notes 1995
879
Notice of Motion to Elaine Chiu, 1997
880
Dupe Family Offense Petition
882
Summons to Dayawathie 1997
884
Summons by Officer Alan Fong on Dayawathie
885
Aftercare plan for Michael upon release from mental hospital
886
Motion for the Appointment of Counsel in this appeal
887
Appeal Scheduling Order
889
Notice of Motion for Custody, July 1997
891
Notice of Appeal, June 1997
901
Letter from Dorchen Leidholdt saying she no longer represents
Dayawathie 902
Letter from Dorchen Leidholdt saying she withdrawing petition
903
Dupe Summons to Dayawathie 1997
904
Letter from Court Attorney to Judge Ross
905
�Help Desperately Needed�
906
Order of commitment 1997
907
DUPE Family Offense Petition
908
DUPR Violation of Order of Protection
911
Letter from Sloan to Natalie Jacobi
914
Court File back cover
916
Family Protection Information Sheet
918
Letter from Sebastian Ike to Judge Kaplan
919
Interview with Petitioner 1991
920
Complaint against Rosemonde Pierre-Louis
927
Letter from Sloan to Elaine Chiu
932
Fax Cover Sheet from Rose Pierre Louis
938
Notice of Appeal August 2006
939
RJI to Appellate Division
940
Ambulance Charges from Court to Elmhurst Hospital
945
Notice of Claim to ACS
947
Notice of Claim to Elmhurst Hospital
948
Notice of Dismissal of Complaint against Rosemonde Pierre-Louis
949
Reply Affidavit on Motion for the Appointment of Counsel
950
Affirmation by Jill Zuccardy in Opposition
954
Psychiatric Evaluation of Samuel Sloan
957
Report of Suspected Child Abuse by Judge Modica Jan 6, 2006
959
GEICO Insurance denial of coverage letter
961
Sandra Car Accident Report
962
GEICO Reply Letters
964
DUPE Sloan letter to Lynchburg J & D Court
970
Sloan letter to Judge Modica, May 2006
972
Sloan letter to Lynchburg J & D Court file stamped
976
Letter from Lynchburg City Attorney to Carla Smith, Clerk
977
Order of Lynchburg Family Court
981
Motion for Judgment Lynchburg Circuit Court
988
Order of Dismissal by Judge Bruce Kaplan
992
Answer in Opposition to Petition for Non-Payment of Rent
993
Order to Show Cause in Appellate Division
996
Notice of Appeal, November 2005
1017
Judge;s Notes, October 2005
1018
DUPE GEICO Acknowledges Claim
1021
Dismissal of Claim against Rosemonde Pierre-Louis
1022
Sloan letter complaining Jessica not allowed to attend school
1023
Summons served on Dayawathie
1026
Blank
1027
Sumy Statement on Application for Expedited Service
1028
Subpoena of Officer Fong
1029
Letter from Cheryl-Joseph Cherry on complains against Judge Modica
1030
Complaint by Sloan against Judge Wong
1031
Answer to Custody Petituion and Counterclaim
1037
Letter from Sloan to Modica May 2006
1043
Letter from Jill Zuccardy to Sloan
1047
DUPE �Help Desperately Needed�
1048
Judges Notes
1049
DUPE Motion to Vacate Ex-Parte TRO
1051
Photos of Sam and his children
1053
POSSIBLE DUPE Letter from Sloan to Judge Ross
1054
POSSIBLE DUPE Temporary Order of Protection Judge Ross
1055
DUPE Judges Notes
1058
Dunning Notice from St. Barnabas Hospital
1060
Notice of Intent to Make Claim Car Accident
1061
Receipt Acknowledgment from GEICO
1063
DUPE Letter from Dorchen to Judge Ross
1069
Student Permanent Record Michael Rankoth Sloan
1070
Subpoena Duces Tecum Long Island City High School
1072
Michael Sloan Birth Certificate
1084
Johnson Housing Project Tenants
1086
Steinway Child and Family Services re Michael Sloan
1087
Temporary Order of Protection October 6, 2005
1089
High School Report Card, Grades of George Rankoth
1092
High School Report Card, Grades of Anusha Rankoth
1093
Letter from Sloan to Robert Hausner
1094
Order to Show Cause by Judge Lenora Gerard
1095
Affidavit of Jill Zuccardy in Support
1097
Salacious articles cited by Jill Zuccardy
1105
United States Chess Federation Rating report for George, Anusha and
Michael 1141
Brief of Appellant Samuel Sloan
1144
Temporary Orders of Protection by Judge Modica
1191
Brief of Petitioner-Appellee Dayawathie Rankoth
1194
Transcript dated January 6, 2006
1219
Decision by Referee Negron
1253
Order to Show Cause of Bronx Supreme Court
1265
Order of Judge Mercorella of Bronx Supreme Court
1266
Order of Bronx Supreme Court giving custody of Shamema to Sam Sloan
1270
Complaint to Virginia Judicial Inquiry and Review Commission
1272
Parental Kidnapping Law Journal Article
1283
State Department Telex re: Roberts claiming custody of Shamema
Honzagool 1284
Birth Certificate of Shamema Honzagool Sloan
1285
Letter from US Embassy in Bangkok, Re: Shamema, Michael and Helen
Sloan 1286
Transcript of Amherst Counts Circuit Court in Commonwealth vs. Sloan
1287
Cover page of Appendix on Appeal
1309
Petition for Rehearing Denied
1310
Petition for rehearing En Banc denied
1311
Motion for Transcript denied
1312
Petition for Mandamus denied
1313
Petition for Custody by Charles and Shelby Roberts
1314
Letter to Judge Trabue
1318
Appointment of Lisa Schenkel as Guardian ad Litem
1320
Letter from Kathy Tomlin Court Secretary
1323
Letter from New York Law Department
1324
Docket Sheet Amherst County Family Court 1986
1326
Order of Amherst County J & D Court
1328
Envelope from Honzagool in Pakistan to Judge Trabue
1331
Letter from Shamema
1332
Letter from Charles & Shelby Roberts to Judge Gamble
1334
Letter of Recusal by Judge Gamble
1335
Order of Recusal by all Lynchburg judges
1336
Notice of Appeal
1337
Order by Judge Gamble dated August 25, 1986
1338
Gulf News article �Missing Girls with US Welfare Agency�
1339
Air ticket from Jay Roberts to bring Shamema and her sister to America
1340
Air transit printout
1341
Motion to Dismiss by US Attorney
1342
Transcript custody of Jessica Sloan
1343
Birth certificate of Shamema
1350
Gulf News article �Father Looking for Missing Children�
1351
Arrest Order for Sloan's Sri Lanka wife
1352
Charles and Shelby Roberts sentenced to Life in Absentia for
Kidnapping 1353
New York Daily News Article: Bought and Enslaved Me: Girl, 19
1354
$10,000 Reward Offered for Return of Shamema
1355
Wanted for Kidnapping: Charles Roberts
1356
Letter from Ismail Sloan to FBI Agent John P. Butler
1357
Letter from BMUMO Black Muslim Underground Militant Organization
1360
Letter from Parole Board: Parole GRANTED
1361
Letter rejecting plea agreement
1363
Order of contempt and removing counsel
1364
Affidavit for Order of Publication by Charles and Shelby Roberts
1366
Addendum to Order of September 4, 1986
1368
Notice from Linda Groome sent to UAE
1369
Gulf News: US Authorities to Drop Kidnapping Charges against Local
Resident 1370
Letter from Fred Hodnett of Supreme Court of Virginia
1371
Letter from Virginia Assistant Attorney General
1372
Letter from Terry Spruce, Court Stenographer
1373
Order granting in part petition for appeal
1374
Order denying motion to Quash indictment
1378
Split Decision of Virginia Court of Appeals affirming conviction by
2-1 vote 1380
Dissenting Opinion by Judge Koontz
1384
Order of Virginia Supreme Court refusing petition for appeal
1386
Letter from Judge Gamble setting trial
1387
Order Granting Petition for Rehearing En Banc
1388
Another Order Granting Petition for Rehearing En Banc
1390
Order Scheduling Rehearing En Banc
1391
Order dismissing Petition for a Writ of Mandamus
1392
Order of Virginia Supreme Court denying petition for appeal
1394
Admission on Bail
1395
Request for Jury Trial
1396
Acknowledgment of letter requesting that Judge Gamble recuse himself
1397
Letter from Judge Gamble scheduling motion that he recuse himself
1398
Letter from Lynchburg Public Defender notifying Sloan of continuation
1399
Order Generally continuing the case
1401
Letter from Virginia Supreme Court Chief Attorney scheduling appeal
1403
Letter from Clerk of Virginia Supreme Court setting hearing date
1404
Offer by Commonwealth of Plea Agreement
1405
Letter from Chief Justice of Virginia Supreme Court Harry Carrico to
Sloan 1407
Letter from Steve tin opposing request by Roberts for Protective
Order 1408
Letter from Amherst Commonwealth Attorney opposing withdrawal of
counsel 1410
Statement of Recusal by Judge Gamble
1411
Waiver of Disqualification requested by Judge Gamble, unsigned
1412
Last Page is 1413
|
| |
Date: 28 Nov 2007 16:56:45
From: Sam Sloan
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
Sam Sloan
1664 Davidson Ave.,
Apt. 1B
Bronx NY 10453-7877
Tel. 917-507-7226
[email protected]
November 27, 2007
Referee Mildred Negron
Queens County Family Court
151-20 Jamaica Avenue
Jamaica NY 11432
Re: Sloan vs. Rankoth, V-11657-05
Rankoth vs. Sloan, O-18182-05
Dear Referee Negron,
You may recall that the court ordered that I would have one visitation
with my daughter Anusha, now aged 15, but then it was reported that
although Anusha came to the scheduled visitation she refused to see
me.
However, I have since learned from other sources that Anusha did not
come alone. She was accompanied by a representative of Dorchen
Leidholdt�s office, although not by Dorchen Leidholdt herself.
My appellate counsel, Pauline Braun, informs me that this was entirely
improper. It was OK for Anusha to be accompanied by her mother,
another close relative or even by the Guardian Ad Litem. However,
Dorchen Leidholdt has been in an adversary relationship with me for 16
years since June 1991 and she had been manipulating and controlling my
children and their mother for that entire time. Indeed, Dorchen
Leidholdt tried to abortion my daughter Anusha, since Dayawathie was
pregnant with Anusha when Dorchen first got involved with her in 1991.
Dayawathie has often told me that the only thing that saved Anusha�s
life was that Dorchen could not arrange the Medicaid in time to pay
for the abortion and by the time the Medicaid was available the
pregnancy was too far advanced for the abortion.
However, Dorchen Liedholdt did abortion our next baby. Dayawathie
became pregnant with our next baby in 1995 and Dorchen had that baby
abortioned on July 7, 1995. The abortion of Sam Sloan's child took
place on July 7, 1995. Almost immediately thereafter, Dayawathie
became pregnant from a passing stranger whose name and identity is
still unknown. That child, Geeta Kamal Rankoth, was born on June 9,
1996, just 11 months after Dayawathie's child by Sam Sloan had been
aborted. By that time, the father of Geeta had long since disappeared.
Geeta, incidentally, is a bright and delightful child.
As to how Dorchen Leidholdt is able to control Dayawathie to the
extent of moving her about, directing where she should live and even
deciding whether she should have an abortion or not, it is a carrot
and stick operation. Dayawathie has been under constant investigation
by ACS since she first arrived in New York in June 1991. She was also
being investigated by Children�s Services in Lynchburg Virginia before
she got here. She has also been threatened with eviction proceedings.
Dorchen Leidholdt appears and defends her in all these cases. I have
some evidence that she actually helps brings these cases that she then
defends her in.
Dorchen Leidholdt had my two sons, Michael and George, kidnapped away
from me in May 1995. We were living in San Francisco with the
knowledge and consent of Dayawathie who was trying to keep this fact a
secret from Dorchen Leidholdt.
This story goes on and on. I could write a book about it and perhaps I
will some day.
What is especially disturbing about Dorchen Leidholdt is that she is
an outspoken advocate of lesbianism. I am a strong believer that
people have a right to adopt their own lifestyles and to fulfill their
own dreams, whatever they may be. I have no objection, none what ever,
to Dorchen Leidholdt being a lesbian. I do object, however, to her
having any involvement in raising my daughter. If you will read her
book, "The Sexual Liberals and the Attack on Feminism", by Dorchen
Leidholdt, you will see her advocating lesbianism and claiming for
example that one-quarter of all girls under age ten have been sexually
molested usually by their own fathers. This is a sick statement for
which she offers no proof. Dorchen Leidholdt has also been personally
involved with infamous pornographers including Linda Lovelace and
Larry Flynt. Before she became a lawyer, her picture was published in
Hustler Magazine. I want this woman kept away from my children and I
have every right to insist on that.
While this case was pending before Judge Modica, I made several
motions to disqualify Dorchen Leidholdt and her representatives,
including Jill Zuccardy and Alexander Karam, from appearing in this
case. These motions were properly served and submitted in open court
by handing them up to the judge. I went to the court last week to look
at the file and found that there was no record of these motions. They
were not in the file or on the docket. Apparently, Judge Modica must
have trashed them.
Apparently, needed to file them with Mr. Sternberg on the first
floor. I did not know about that. I naturally assumed that handing
them up to the judge in open court was an effective way to file these
motions. I ask that you consider these motions now.
Also, I ask that you reschedule my visitation with Anusha and direct
Dorchen Leidholdt and her representative to stop interference with
this case.
Every time I bring up Dorchen Leidholdt I am told that she is not in
this case. But, she is in this case. Dorchen Leidholdt is the 800
pound gorilla in the room. She controls Dayawathie Rankoth. She hires
and fires Jill Zuccardy, Paul Weiss and the other attorneys who appear
in this case, and every time I try to ask Dayawathie a question about
Dorchen Leidholdt the attorneys object on the grounds of
attorney-client privilege, yet the name of Dorchen Leidholdt has never
appeared on any of these cases.
I have never met or seen Dorchen Leidholdt. I have no idea what she
looks like. I know her role in this case because Dayawathie talks
about her and often complains about her all the time. This case will
never be resolved and will go on forever as long as Dorchen Leidholdt
is allowed to hide behind a screen while controlling and manipulating
everything.
Accordingly, I am renewing my motions previously filed with Judge
Modica to remove Dorchen Leidholdt from this case.
I also object that every time that Jill Zuccardy announces her
appearance in this case she states that she is representing Sanctuary
for Families. Center for Battered Women�s Legal Services. This creates
the misleading impression that Dayawathie Rankoth is a battered woman.
However, there is no allegation, much less evidence that she has ever
been battered by me. Also, the 990 Form for Sanctuary for Families
shows that Dorchen Leidholdt pays herself a salary of $111,067 per
year. She is just using my family as poster children so that she can
obtain charitable contributions and this is highly objectionable.
Then, she uses this as a pretext to get Paul, Weiss, Rifkind, Wharton
& Garrison to represent Dayawathie Rankoth on the appellate level.
On May 2, 2006 in an article in the New York Law Journal in response
to criticism of the judges in the Queens Family Court, Dorchen
Leidholdt was quoted as saying that most of the judges are bad, but
there is one good judge and that is Judge Modica. I would like to draw
your attention to that quote.
Very Truly Yours,
Samuel H. Sloan
Copy to:
Jill Zuccardy
Vladimir Cadet
Janet L. Brown
Pauline Braun
Paul, Weiss, Rifkind, Wharton & Garrison LLP
P.S. While not relevant to this case, I think I should inform you that
there has been a lot of media publicity recently about the fact that a
person has been positively identified as having impersonated me in
2464 postings on the Internet.
The lead article on this subject appeared in the New York Times on
October 8, 2007 entitled: NY Times: "Chess Group Officials Accused of
Using Internet to Hurt Rivals"
AFFIDAVIT OF SERVICE
Docket No. V-11567-05
STATE OF NEW YORK
COUNTY OF QUEENS
Kayo Kimura, being duly sworn says: I am not a party to this action, I
am over 18 years of age and on November 27, 2007 at 8:00 AM I served a
true copy of the within motion by mailing a true copy of the same to:
Jill Zuccardy
Sanctuary for Families
67 Wall Street, Room 2211
New York NY 2006
Vladimir Cadet
89-31 161st Street, Suite 505
Jamaica NY 11432
Janet Lisa Brown
89-31 161st Street, Suite 301
Jamaica, NY 11432-6150
Paul, Weiss, Rifkind, Wharton & Garrison LLP
1285 Avenue of the Americas
New York, NY 10019-6064
__________________________
Sworn to Before me this 27th
Day of November, 2007
______________________________
NOTARY PUBLIC
|
| |
Date: 27 Nov 2007 21:15:21
From: GeekBoy
Subject: Re: Complaint to Referee Mildred Negron regarding Dorchen Leidholdt
|
"Spam Sloan" <[email protected] > wrote in message
news:[email protected]...
> Sam Sloan
> 1664 Davidson Ave., Apt. 1B
> Bronx NY 10453-7877
>
GO AWAY DICK SUCKING SPAMMER
> Tel. 917-507-7226
> [email protected]
>
> November 27, 2007
>
> Referee Mildred Negron
> Queens County Family Court
> 151-20 Jamaica Avenue
> Jamaica NY 11432
>
> Re: Sloan vs. Rankoth, V-11657-05
> Rankoth vs. Sloan, O-18182-05
>
> Dear Referee Negron,
>
> You may recall that the court ordered that I would have one visitation
> with my daughter Anusha, now aged 15, but then it was reported that
> although Anusha came to the scheduled visitation she refused to see
> me.
>
> However, I have since learned from other sources that Anusha did not
> come alone. She was accompanied by a representative of Dorschen
> Leidholdt's office, although not by Dorschen Leidholdt herself.
>
> My appellate counsel, Pauline Braun, informs me that this was entirely
> improper. It was OK for Anusha to be accompanied by her mother,
> another close relative or even by the Guardian Ad Litem. However,
> Dorschen Leidholdt has been in an adversary relationship with me for
> 16 years since June 1991 and she had been manipulating and controlling
> my children and their mother for that entire time. Indeed, Dorschen
> Leidholdt tried to abortion my daughter Anusha, since Dayawathie was
> pregnant with Anusha when Dorchen first got involved with her in 1991.
> Dayawathie has often told me that the only thing that saved Anusha's
> life was that Dorschen could not arrange the Medicaid in time to pay
> for the abortion and by the time the Medicaid was available the
> pregnancy was too far advanced for the abortion.
>
> However, Dorschen Liedholdt did abortion our next baby. Dayawathie
> became pregnant with our next baby in 1995 and Dorshen had that baby
> abortioned on July 7, 1995. The abortion of Sam Sloan's child took
> place on July 7, 1995. Almost immediately thereafter, Dayawathie
> became pregnant from a passing stranger whose name and identity is
> still unknown. That child, Geeta Kamal Rankoth, was born on June 9,
> 1996, just 11 months after Dayawathie's child by Sam Sloan had been
> aborted. By that time, the father of Geeta had long since disappeared.
>
> Geeta, incidentally, is a bright and delightful child.
>
> As to how Dorschen Leidholdt is able to control Dayawathie to the
> extent of moving her about, directing where she should live and even
> deciding whether she should have an abortion or not, it is a carrot
> and stick operation. Dayawathie has been under constant investigation
> by ACS since she first arrived in New York in June 1991. She was also
> being investigated by Childrens Services in Lynchburg Virginia before
> she got here. She has also been threatened with eviction proceedings.
> Dorschen Leidholdt appears and defends her in all these cases. I have
> some evidence that she actually helps brings these cases that she then
> defends her in.
>
> Dorschen Leidholdt had my two sons, Michael and George, kidnapped away
> from me in May 1995. We were living in San Francisco with the
> knowledge and consent of Dayawathie who was trying to keep this fact a
> secret from Dorschen Leidholdt.
>
> This story goes on and on. I could write a book about it and perhaps I
> will some day.
>
> What is especially disturbing about Dorschen Leidholdt is that she is
> an outspoken advocate of lesbianism. I am a strong believer that
> people have a right to adopt their own lifestyles and to fulfill their
> own dreams, whatever they may be. I have no objection, none what ever,
> to Dorschen Leidholdt being a lesbian. I do object, however, to her
> having any involvement in raising my daughter. If you will read her
> book, "The Sexual Liberals and the Attack on Feminism", by Dorschen
> Leidholdt, you will see her advocating lesbianism and claiming for
> example that one-quarter of all girls under age ten have been sexually
> molested usually by their own fathers. This is a sick statement for
> which she offers no proof. Dorschen Leidholdt has also been personally
> involved with infamous pornographers including Linda Lovelace and
> Larry Flynt. I want this woman kept away from my children and I have
> every right to insist on that.
>
> While this case was pending before Judge Modica, I made several
> motions to disqualify Dorschen Leidholdt and her representatives,
> including Jill Zuccardy and Alexander Karam, from appearing in this
> case. These motions were properly served and submitted in open court
> by handing them up to the judge. I went to the court last week to look
> at the file and found that there was no record of these motions. They
> were not in the file or on the docket. Apparently, Judge Modica must
> have trashed them.
>
> Apparently, needed to file them with Mr. Sternberg on the first
> floor. I did not know about that. I naturally assumed that handing
> them up to the judge in open court was an effective way to file these
> motions. I ask that you consider these motions now.
>
> Also, I ask that you reschedule my visitation with Anusha and direct
> Dorschen Leidholdt and her representative to stop interference with
> this case.
>
> Every time I bring up Dorschen Leidholdt I am told that she is not in
> this case. But, she is in this case. Dorschen Leidholdt is the 800
> pound gorilla in the room. She controls Dayawathie Rankoth. She hires
> and fires Jill Zuccardy, Paul Weiss and the other attorneys who appear
> in this case, and every time I try to ask Dayawathie a question about
> Dorschen Leidholdt the attorneys object on the grounds of
> attorney-client privilege, yet the name of Dorschen Leidholdt has
> never appeared on any of these cases.
>
> I have never met or seen Dorschen Leidholdt. I have no idea what she
> looks like. I know her role in this case because Dayawathie talks
> about her and often complains about her all the time. This case will
> never be resolved and will go on forever as long as Dorschgen
> Leidholdt is allowed to hide behind a screen while controlling and
> manipulating everything.
>
> Accordingly, I am renewing my motions previously filed with Judge
> Modica to remove Dorschen Leidholdt from this case.
>
> I also object that every time that Jill Zuccardy announces her
> appearance in this case she states that she is representing Sanctuary
> for Families. Center for Battered Women's Legal Services. This creates
> the misleading impression that Dayawathie Rankoth is a battered woman.
> However, there is no allegation, much less evidence that she has ever
> been battered by me. Also, the 990 Form for Sanctuary for Families
> shows that Dorschen Leidholdt pays herself a salary of $111,067 per
> year. She is just using my family as poster children so that she can
> obtain charitable contributions and this is highly objectionable.
> Then, she uses this as a pretext to get Paul, Weiss, Rifkind, Wharton
> & Garrison to represent Dayawathie Rankoth on the appellate level.
>
> On May 2, 2006 in an article in the New York Law Journal in response
> to criticism of the judges in the Queens Family Court, Dorschen
> Leidholdt was quoted as saying that most of the judges are bad, but
> there is one good judge and that is Judge Modica. I would like to draw
> your attention to that quote.
>
>
> Very Truly Yours,
>
>
>
> Samuel H. Sloan
>
> Copy to:
>
> Jill Zuccardy
> Vladimir Cadet
> Janet L. Brown
> Pauline Braun
> Paul, Weiss, Rifkind, Wharton & Garrison LLP
>
>
> P.S. While not relevant to this case, I think I should inform you that
> there has been a lot of media publicity recently about the fact that a
> person has been positively identified as having impersonated me in
> 2464 postings on the Internet.
>
> The lead article on this subject appeared in the New York Times on
> October 8, 2007 entitled: NY Times: "Chess Group Officials Accused of
> Using Internet to Hurt Rivals"
>
>
>
>
>
> AFFIDAVIT OF SERVICE
>
> Docket No. V-11567-05
>
> STATE OF NEW YORK
> COUNTY OF QUEENS
>
> Kayo Kimura, being duly sworn says: I am not a party to this action, I
> am over 18 years of age and on November 27, 2007 at 8:00 AM I served a
> true copy of the within motion by mailing a true copy of the same to:
>
> Jill Zuccardy
> Sanctuary for Families
> 67 Wall Street, Room 2211
> New York NY 2006
>
> Vladimir Cadet
> 89-31 161st Street, Suite 505
> Jamaica NY 11432
>
> Janet Lisa Brown
> 89-31 161st Street, Suite 301
> Jamaica, NY 11432-6150
>
> Paul, Weiss, Rifkind, Wharton & Garrison LLP
> 1285 Avenue of the Americas
> New York, NY 10019-6064
>
>
>
> __________________________
>
> Sworn to Before me this 27th
> Day of November, 2007
>
>
> ______________________________
> NOTARY PUBLIC
|
|
